Giammarco CottaniGiammarco Cottani is a partner at the Ludovici and Partners tax firm, where he coordinates the transfer pricing practice with regard to both the prevention and resolution of domestic and international disputes and assistance in complex audits of large multinational enterprise groups. He holds an LLM cum laude in European and international taxation from the European Tax College of Leuven (Belgium) and Tilburg (the Netherlands), and a PhD in corporate taxation from the LUISS University, Rome. From 2011 to July 2015, he held the role of advisor to the Italian Revenue Agency’s Director of Central Assessment on international tax and transfer pricing. He focused on international tax issues related to large multinational groups and SMEs. He was one of the delegates for Italy in the OECD-G20 Action Plan on BEPS. From 2009 to 2011, he was employed as a transfer pricing advisor in the transfer pricing unit of the OECD where he was involved in the introduction of the new Chapter IX of the OECD Transfer Pricing Guidelines concerning business restructuring. He currently serves as a member of the UN Sub-Committee Group on transfer pricing which is supervising drafting the Practical Manual on Transfer Pricing for Developing Countries.
Transfer pricing is one of the most relevant and challenging topics in the international tax environment. The increasing global trade and the role of multinational enterprises in the global economy have boosted the importance of this topic. This lecture will provide the students with the fundamental tools to understand transfer pricing topics and the arm’s length principle, both from a legal and an economic perspective. The theoretical analysis will be supported by examples and cases coming from practice. Particular focus will be given to the relevance of the comparability analysis in light of the new approach envisaged by the BEPS Report on Actions 8, 9 and 10 and an overview on the selection of the most appropriate transfer pricing methods.
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