Transfer Pricing 2026

INTRODUCTION  Contributed by: Paolo Ludovici, Luca Tortorella, Marlinda Gianfrate and Angelica Masciulli, Gatti Pavesi Bianchi Ludovici

Marlinda Gianfrate has been an of counsel at Gatti Pavesi Bianchi Ludovici since 2022 and is involved in various projects concerning international tax issues. With an economics background, she deals

Angelica Masciulli has been working at Gatti Pavesi Bianchi Ludovici since 2021, focusing on transfer pricing and international taxation. She advises leading multinational groups in the industrial and financial sectors on

with international taxation, with a focus on transfer pricing, APAs, MAPs and co-operative compliance programmes. Marlinda worked for the Italian tax administration for 17 years, most recently holding the position of head of the Advance Agreements Office of the Revenue Agency. She was also assigned to represent Italy at the OECD’s CFA Working Party No 6 (on the taxation of multinational enterprises), contributing to work related to the BEPS Project, the update of the OECD TP Guidelines and the two-pillar solution.

documentation matters, as well as pre-litigation and APA settlement procedures with the tax authorities. Before joining Gatti Pavesi Bianchi Ludovici, Angelica worked at an international tax and law firm as a transfer pricing specialist, assisting financial and industrial clients. She graduated cum laude in economics and business law in 2017 and holds a master’s degree in tax law. She is a member of the Association of Chartered Accountants.

Gatti Pavesi Bianchi Ludovici Piazza Borromeo 8 20123 Milano Italy

Tel: +39 02 859751 Fax: +39 02 809447 Email: studio@gpblex.it Web: www.gpblex.it

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