Aldo Castoldi, Deloitte Italy, is a partner, and the leader of the transfer pricing practice in Italy. He has 18 years of international tax experience, and he has served a wide range of foreign-owned multinationals, as well as Italian concerns.
Aldo has extensive experience in transfer pricing and international tax issues. Since the establishment of Deloitte's Italian transfer pricing service line in 1999, Aldo has been in charge of all major transfer pricing projects carried out by Deloitte in Italy. He has worked for a large number of Italian, European, U.S. and Far-East multinationals in a wide range of industries, including the chemical, consumer goods, software, life sciences, electronics, e-commerce, and TMC industries. Aldo has gained significant experience both in performing and coordinating comprehensive transfer pricing studies, planning, documentation, and litigation projects, as well as providing consultancy to multinational corporations in the context of business model optimization restructuring projects. Furthermore, Aldo has got a significant expertise in managing "Competent Authority" procedures, pioneering the negotiation of both unilateral and multilateral APAs in Italy, and concluding the first ever EU Arbitration Convention procedure triggered by an Italian Tax Agency's TP adjustment.
Transfer Pricing Expertise
- Responsible for a large number of transfer pricing documentation Studies, including "Global Dox")
- Development of transfer pricing models for distribution and manufacturing businesses in different industries
- Design and implementation of cost sharing agreements, stripped distributors, and commissionaire agreements
- Analysis and advice on permanent establishment issues and planning
- Project management of supply-chain restructurings involving Italian-based multinationals
- Analysis and planning of intangibles transactions for tax reduction and global earnings mobilization purposes;
- Assistance to clients in tax litigation concerning transfer pricing issues and preparation and filing of international tax rulings requests with the Italian tax authorities;
- Preparation, filing, and management of tax treaty mutual agreement procedures and EU Arbitration procedures
- Negotiation of unilateral and multilateral advance pricing Agreements
University Degree in Economics, Master's Degree in Tax Law, Chartered Accountant (Dottore Commercialista), Italian Chartered Auditor.