Transfer Pricing 2025

INTRODUCTION

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

Gatti Pavesi Bianchi Ludovici is a full-service independent law and tax firm with 200 profes - sionals that has offices in Milan, Rome and London. The firm provides expert guidance and assistance to national and international clients and institutions across all areas of civil, com - mercial and corporate law, as well as in all the fields of domestic and international taxation. With a fully dedicated team, GPBL provides comprehensive support to multinational groups across all areas of transfer pricing, including the definition of transfer pricing policies, optimisa - tion of supply chain models, cross-border re -

structurings, negotiation of unilateral/bilateral/ multilateral APAs with authorities and drafting of compliance documentation. The team is in - volved in complex transfer pricing litigation and joint audits, also offering support in pre-litiga - tion settlement procedures and MAP. The firm also assists with the International Compliance Assurance Programme (ICAP). By capitalising on strong professional relationships with top- tier firms worldwide, GPBL supports clients ef - fectively across multiple regions and seamlessly co-ordinates multi-jurisdictional teams.

Contributing Editors

Paolo Ludovici has been a partner of Gatti Pavesi Bianchi Ludovici since 2021 following its merger with L&P, which he founded in 2014. Previously, he worked for 23 years at Maisto e

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

Associati, becoming a partner in 2000. Paolo’s expertise includes domestic and international corporate reorganisations, M&A and structured finance transactions, and tax planning for HNWI and trusts. Admitted to the Chartered Accountants Association in Milan, he is vice president of the Tax & Legal & Compliance Commission at AIPB and a member of the Tax Commission at AIFI, Invest Europe and the technical committee for implementing personal income tax reform set up by the Ministry of Economy and Finance in 2023.

background, she deals 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.

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