Federico Pacelli

Federico Pacelli is a Partner in the Tax department and is responsible for the transfer pricing practice and the cooperative compliance team in Italy.

Throughout his professional career, he has gained extensive experience in corporate taxation, with a particular focus on international tax matters and the management of tax compliance programs.

With specific reference to the transfer pricing practice, he has assisted both Italian and foreign multinational groups in managing transfer pricing risk, both “preventively” (e.g., APAs, structuring of group transfer pricing policies, etc.) and “subsequently” (e.g., pre-litigation, litigation, mutual agreement procedures).

Since the earliest practical applications in Italy, Federico has supported multinational groups in all activities related to the implementation and development of the Tax Control Framework (TCF) (including the implementation and updating of the tax risk management and control model, testing activities, and the management of interpretative risk) both for the purposes of joining the Cooperative Compliance regime and for the purposes of exercising the two-year option for certified TCF, as well as, more generally, for effective tax risk management.

In this area, he has also assisted multinational groups within international tax compliance programs (e.g., ICAP) and carries out certification and attestation activities on tax risk management and control systems, as he is registered in the dedicated professional register. He also serves as Chair of the TCF Committee of an Italian company under the Cooperative Compliance regime, part of a leading multinational group in the food sector.