Milan hosted a new international meeting dedicated to Transfer Pricing and international taxation. At Crowe Valente’s International Research Center, a specialist workshop welcomed a delegation of 23 tax professionals from the Mongolian Association of Certified Tax Consultants (MACTC).

The initiative builds on the professional exchange and cooperation already established with MACTC and confirms Crowe Valente’s commitment to promoting specialist training and international dialogue on key tax issues.

The workshop was led by Prof. Piergiorgio Valente, who, together with his colleagues Federico Vincenti, Carola Valente Della Rovere and Sara Parillo, guided participants through an in-depth exploration of transfer pricing, with a particular focus on the relationship between value creation, economic substance, financial transactions and documentation. The workshop, entitled “Transfer Pricing: DEMPE, Financial Transactions & Documentation”, combined theoretical principles, practical applications and case studies relating to international structures.

During the session, participants explored some of the most relevant topics in international Transfer Pricing, including:

• the arm’s length principle and comparability analysis
• Value Creation, FAR analysis and DEMPE functions, with particular attention to the appropriate allocation of returns from intangibles
• intra-group financial transactions, including loans, cash pooling and guarantees
• Transfer Pricing documentation under the OECD BEPS Action 13 framework
• audit readiness, governance and the preparation of evidence consistent with the economic substance of transactions

Particular attention was devoted to the principle that the appropriate allocation of profits should reflect the functions actually performed, assets used and risks assumed and controlled, as well as the importance of ensuring consistency between contractual arrangements, actual conduct and supporting documentation. With regard to financial transactions, the workshop examined the “delineate, price, evidence” approach, highlighting the importance of assessing the substance of transactions, risk control, realistically available alternatives and market benchmarks.

The workshop provided another valuable opportunity for technical discussion and knowledge sharing between Europe and Mongolia, encouraging dialogue on international best practices and on how businesses and professionals can address a tax environment increasingly focused on transparency, economic substance and effective governance.

The meeting further strengthens the collaboration with the Mongolian Association of Certified Tax Consultants and highlights the role of international training as a means of developing expertise, sharing professional experience and strengthening relationships among professionals operating within different tax systems.

Special thanks go to MACTC and the 23 members of the delegation for their active participation, valuable insights and contribution to the success of the workshop.