All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

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 from across our site

This week European Commission officials consider legal loopholes to secure minimum corporate taxation, while Cisco and Microsoft shareholders call for tax transparency.
The fast-food company’s tax settlement with French authorities strengthens the need for businesses to review their TP arrangements and documentation.
The full ALP model will be adopted through a new TP regime, which is set to boost the country’s investments and tax certainty.
Tax professionals have called on the UK government to reconsider its online sales tax as it would affect the economy at the worst time.
Tax professionals have called on companies to act urgently to meet e-invoicing compliance targets as the EU plans to ramp up digitisation.
In the wake of India’s ambitious 25-year plan for economic growth, ITR has partnered with leading tax commentators to discuss what the future will look like for India and for the rest of the world.
But experts cast doubt on HMRC's data and believe COVID-19 would have increased the revenue shortfall.
EY’s plan to separate its auditing and consulting businesses might lessen scrutiny from global regulators, but the brand identity could suffer, say sources.
Multinationals are asking world leaders to put a scale on carbon pricing to tackle climate change at the 48th G7 summit in Germany, from June 26 to 28.
The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree