Federico Pacelli is a Partner in the Tax department and is responsible for the Italian transfer pricing practice. With reference to this specific area of activity, Federico has gained a consolidated experience, assisting Italian and foreign multinationals operating in different sectors (for example, luxury, pharmaceutical, food & beverage, chemical and industrial) in defining their transfer pricing policy and in the management of the related risk of double taxation, both in a preventive way (unilateral and multilateral APA) and subsequent to the related occurrence (MAP and litigation).
Federico has a consolidated experience in the field of tax law, in particular provides advice to multinational companies for direct and indirect taxation, also in the context of corporate reorganization and acquisition operations, with reference to both domestic and transnational issues (for eg disputes concerning tax residence, permanent establishment, application of Community Directives and double taxation agreements).
Furthermore, Federico is responsible for the preparation of tax control framework systems, also for the purpose of joining the cooperative compliance program envisaged by Italian law, as well as for the preparation and presentation of requests for interpolation with reference to problems of a different nature.