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.”