Transfer Pricing 2026

ITALY Law and Practice Contributed by: Marco Valdonio and Gabriella Cappelleri, Maisto e Associati

Maisto e Associati was established in 1991 as an independent Italian tax law firm with offices in Mi - lan, Rome and London. Over the years, the firm has grown consistently and now has over 70 profession - als, including 16 partners and two of counsel, with consolidated experience in managing complex do - mestic and multi-jurisdictional cases. It has a long tradition of transfer pricing work, with a dedicated team that has depth of expertise in assisting multina - tional groups with reference to all issues in this field.

Maisto e Associati has an outstanding track record in the negotiation of unilateral and bilateral advance pricing agreements, requests for unilateral recogni - tion of the downward adjustment of the income of a resident company following a transfer pricing ad - justment carried out by the fiscal administration of another state, competent authorities procedures for the management of tax disputes concerning the ad - justment of the profits of associated companies, and assistance on transfer pricing audits. Gabriella Cappelleri is of counsel at Maisto e Associati. Her areas of expertise are international taxation and transfer pricing. She joined the firm as of counsel in December 2015, having previously served as head of the APA Office at the Italian Revenue Agency, where she was responsible for APA procedures and transfer pricing matters, as well as for drafting regulations and other guidance. Gabriella was the delegate for Italy at the OECD’s Working Party No 6, which was responsible for updating the OECD Transfer Pricing Guidelines, and a member of the working party set up by the Italian Revenue Agency for the implementation of the OECD-G20 Action Plan on the BEPS project in Italy.

Authors

Marco Valdonio is a partner of Maisto e Associati with a wide range of skills in transfer pricing matters, including drafting and negotiating APAs and agreements with the Italian Revenue Agency, the definition of tax

controversies through settlement procedures, as well as extraordinary transactions. He advises clients on the tax aspects of M&A, taxation of financial instruments and real estate transactions. His activity also covers assistance on international taxation matters. He was admitted to the Association of Chartered Accountants in 2002. He joined Maisto e Associati in 2000, after working for another tax law firm and has been a partner since 2011.

Maisto e Associati Piazza Filippo Meda 5 20121 Milano Italy Tel: +39 0277 69 31 Fax: +39 0277 69 3300

Email: info@maisto.it Web: www.maisto.it

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