Extraordinary result for STUDIO DE GIORGI e ASSOCIATI

Member News
November 11, 2021 - STUDIO DE GIORGI e ASSOCIATI

We are delighted to share STUDIO DE GIORGI e ASSOCIATI's recent extraordinary result in resolving a tax assessment challenge, and their approach to this challenge.

A client of STUDIO DE GIORGI e ASSOCIATI recently received a tax assessment challenge on transfer pricing, which would have resulted in a hefty fine plus additional penalties. Through this request, STUDIO DE GIORGI e ASSOCIATI were challenged on the consistency of the company's data that they had produced, and were criticized on both the system adopted and the benchmark analysis that had been accurately completed by the firm. 

As a result of this challenge, STUDIO DE GIORGI e ASSOCIATI initiated a double exercise to protect their clients' interests and to establish the correctness of their behavior and data:

  • Firstly, they kept in close connection with the organization who had issued the challenge, supplying them with the data supporting their calculations. This was not easy during the COVID period due to restrictions and limitations for in person meetings.
  • Secondly, they worked closely with three different departments of the company involved in the case, located across three European countries, dismantling and then reassembling all the information collected and supplied to the organization.

An additional difficulty they experienced arose from the fact that personnel at the organization issuing the challenge were sometimes unfamiliar with the English language, which caused issues due to all of STUDIO DE GIORGI e ASSOCIATI's documents and reports being in English. STUDIO DE GIORGI e ASSOCIATI resolved this issue by acting as interpreters in certain cases. 

After several months of work, explanations and negotiations, STUDIO DE GIORGI e ASSOCIATI successfully established the correctness of their behavior and their data, to the extent that the challenging organization waived their claim entirely and issued a final 'clean' report, without any increase of tax base, nor penalties. The changes suggested through the challenge could have triggered a hefty increase of the taxable income, with consequent taxes in excess of €650,000, plus additional penalties and interests applicable, and this is therefore an extraordinary result in terms of pre-litigation with tax authorities. It is also the second time in a row STUDIO DE GIORGI e ASSOCIATI has closed a transfer pricing tax assessment with no additions to the tax base, highlighting the firm's expertise in this area. In addition, this is a great example of how PrimeGlobal member firms are supporting businesses and enabling international development.

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STUDIO DE GIORGI e ASSOCIATI is a professional firm of accountants and auditors focused on national and international tax and company law, on company administration matters, and on individuals’ tax planning. We normally do business in English, currently spoken by most of our staff, as well as in other foreign languages. We assist our clients with financial, administrative and fiscal support, dealing with yearly tax returns, financial reporting, accounting, payroll, bookkeeping, company management and cost controlling, in general.

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