During the course of tax audits, Italian tax authorities often challenge the value of the goods or services subject to intra-group relationships.
These disputes are particularly relevant for the Italian entity/company that carries out such inter-company transactions.
Should there be no coincidence between the declared assessments and the assessments made – based on Article 9 Testo unico delle imposte sui redditi (TUIR) – potential liability scenarios related to the crime of unfaithful declaration could open up.
Pubblicato su: International Tax Review (ITR) – 15 Aprile 2020