By Gerson, Preston, Klein, Lips, Eisenberg & Gelber
Cross-border business operations between Italy and the United States create unique opportunities for strategic tax planning. While transfer pricing is often viewed primarily as a compliance matter, forward-thinking companies recognize it as a powerful tool for enhancing profitability and optimizing global tax positions.
The international business landscape has evolved significantly in recent years, with Italian companies expanding their US presence across diverse sectors including manufacturing, luxury goods, yachting, and food & beverage. These expansions create complex intercompany relationships that, when thoughtfully structured, can yield substantial economic benefits.
At a recent business forum, Nicolò Fabbrizio, Partner at Gerson Preston Klein Lips Eisenberg & Gelber, noted how transfer pricing strategy has become a crucial element of financial planning for international businesses. “When properly implemented, strategic transfer pricing aligns business objectives with tax efficiency, creating value beyond mere compliance,” Fabbrizio explained. “Companies that view transfer pricing proactively often discover it can be a competitive advantage.”
The firm’s approach focuses on identifying opportunities within legitimate transfer pricing methodologies that align with business realities while optimizing tax positions. This might include strategic placement of intellectual property, thoughtful structuring of management services, or appropriate allocation of risk and reward across jurisdictions.
Michael Desaulniers, CVA, who leads the firm’s Valuation & Transfer Pricing practice, emphasizes the importance of substance in these arrangements. “The most successful strategies are those built on genuine business operations, not artificial constructs,” he notes. “Our expertise lies in identifying authentic opportunities that reflect operational realities.”
Italian businesses navigating these complexities benefit from advisors with deep understanding of both US and Italian tax systems and cultural nuances. By taking a strategic approach, companies can transform a potential compliance burden into a value-creation opportunity.
For more insights on transfer pricing strategies, Nicolò Fabbrizio (nif@gpkleg.com) and Michael Desaulniers (mjd@gpkleg.com) can be reached at 305-868-3600.