A rigorous business valuation requires strong technical methodologies and alignment with tax regulations. At ALS Value, we combine models such as discounted cash flow and market multiples to ensure defensible transaction prices during inspections, guaranteeing financial accuracy and tax compliance.
The OECD has published new guidelines on the Global Minimum Tax, and Spain has passed Law 7/2024 to implement Pillar Two. These measures require multinationals to adapt their tax structures, meet new reporting obligations, and prepare for an effective minimum taxation of 15%.
Brazil adopts the arm’s length principle and aligns its transfer pricing regime with OECD guidelines. The reform introduces new valuation methods, stricter documentation requirements, and penalties—marking a key shift for multinationals operating in the country. ALS offers strategic support for implementation and compliance.
The assignment of image rights between artists or athletes and their own companies raises complex tax challenges. Current case law supports these operations if they are valued at arm’s length, but requires personal income tax to be applied to income from highly personal services performed directly by the individual.
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The Italian Revenue Agency and the Supreme Court endorse the use of the full range as a valid criterion to determine the arm’s length value in transfer pricing. This position, aligned with OECD guidelines, strengthens legal certainty for multinationals and clarifies the use of full ranges over more restrictive approaches such as the median.