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Marco Orlandi

Transfer Pricing Director
Baker & McKenzie Amsterdam N.V.
Not admitted to practice law in this jurisdiction


Marco Orlandi is a Transfer Pricing Director in the Tax practice group of Baker McKenzie in Amsterdam.

Practice Focus

Marco has gained extensive experience in dealing with international corporate taxation and transfer pricing, from both a professional and a government perspective.

In particular, Marco advises clients on specific topics (e.g. international tax issues and transfer pricing issues related to services, permanent establishments, financing, business restructuring, intangibles, and indirect taxes), as well as assists them in litigation, APA and MAP procedures.

From 2011 to 2016, he also served the Italian Revenue Agency being responsible for auditing large multinationals on transfer pricing and on international tax issues. In 2013, he took part to the first joint audit pilot project between the German tax administration and the Italian Revenue Agency, and in 2015 he was appointed as expert in the Tax Inspectors Without Borders Project promoted by OECD and UNPD, where he was responsible for providing technical assistance to the Albanian General Taxation Directorate.

Marco is a frequent speaker in national and international conferences and lecturer of numerous courses for tax administrations (Albania, Azerbaijan, Basque Country, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Greece, Poland) on the behalf of governments and international organizations. He is also author of several publications on international tax and transfer pricing topics.

Professional Associations and Memberships

  • Member of the Board of the Italian Branch of the IFA Young Network (since 2019)
  • Expert, Tax Inspectors Without Borders – Pilot Project Promoted by UN and OECD Between Italy and Albania (2015-2016)
  • Joint Audit Team Leader, Joint Audit Pilot Project Italy – Germany (2013-2015)


  • Italy (2009)


  • Vienna University of Economics and Business (Master of Laws - International Business, Trade and Tax Law) (2019)
  • Cà Foscari University (Master of Science in Economics and Business Science) (2007)
  • Cà Foscari University (Degree in Economics and Business Science) (2004)


  • Italian
  • English

Previous Offices

  • Milan


  • Co-author, ‘Transfer Pricing Methods (Part I): Traditional Transaction Methods’, in: Lang, Cottani, Petruzzi, Storck (eds), Fundamentals of Transfer Pricing: A Practical Guide (Vienna: Wolters Kluwer, 2018).
  • Author., Article 8: ‘Are the Underlying Reasons for Granting a Special Rule Still Valid?’ in: Binder, Wohrer (eds), Special Features of the UN Model Convention (Vienna: Linde, 2019).

Articles in Journals

  • Author, ‘Joint Audit: A New Tool to Combat Cross-Border Tax Evasion’, Insight - The Tax Journal of Ruchelman P.L.L.C (2018) Vol. 5 No. 6. p. 26 (32).
  • Author, ‘l’impatto del Beps nei gruppi della moda’, Novità fiscali – l’attualità del diritto tributario svizzero e internazionale, n. 2 (2019), p. 70 (76).
  • Co-author, “The Role of Bankability Opinions in a Proper Transfer Pricing Analysis for Intragroup Loans”, Tax Notes International, June 29 (2020), p. 1515.
  • Author, "Comparability Analysis under COVID-19 Circumstances in Light of the OECD Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic", International Transfer Pricing Journal, 2021 (Volume 28), No. 2