Author: Piergiorgio Valente
Before 2014, IRAP (the Italian Regional Tax on Productive Activities) regulations gave rise to some interpretative difficulties when transfer pricing issues were involved, especially during tax audits and assessments.
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Author: Piergiorgio Valente
Piergiorgio Valente, managing partner of Valente Associati GEB Partners, discusses a Supreme Court ruling (17955/2013) and its impact on the arm’s-length principle.
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Author: Piergiorgio Valente
Practitioners should pay attention to the observations outlined below to avoid being criminally charged in cases involving transfer pricing litigation.
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Author: Piergiorgio Valente
The assignment of profits and the formation of the so-called “endowment fund” of permanent establishments must occur following a detailed functional analysis and the comparability analysis…
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