Fiat’s Andrea Bonzano talks BEPS, formulary apportionment and the profit split method

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Fiat’s Andrea Bonzano talks BEPS, formulary apportionment and the profit split method

Andrea Bonzano, head of tax at Fiat, discusses the pros and cons of different transfer pricing methods in an interview with TPWeek, and provides his views on BEPS and US inversions.

Bonzano has expressed his views on some of the most topical transfer pricing issues, discussing his concerns over BEPS and country-by-country reporting. Bonzano also addresses the issue of commercial sensitivity in documentation requirements and the reasons behind US inversion transactions.

Bonzano has spoken at length with TPWeek about the inner workings of Fiat’s tax department and day-to-day transfer pricing challenges.

The interview provides an inside look into Fiat’s tax strategy, including its organisational structure and preferred transfer pricing methodologies.

“Fiat finds the profit split method to be the most appropriate in many peculiar situations. When intangibles are directly or indirectly contributed by both parties of a transaction, profit split is the only methodology that allows for the measurement of the arm’s-length weight of the two contributors,” said Bonzano.

Bonzano also addresses the burden of proposed BEPS documentation requirements and provides a largely contrasting view from other taxpayers with regards to commercial sensitivity.

I think the first reaction from taxpayers is that we are already providing enough, don’t ask us to be more proactive.”

The full interview is available on TPWeek.

Register for a free trial on TPWeek to read Andrea Bonzano’s comments in full.

more across site & shared bottom lb ros

More from across our site

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
Gift this article