Published in: Intertax – Volume 41 January 2013
The Italian Tax Authorities encounter difficulties in supporting their own transfer pricing audits in an unassailable manner, which is by no means a lesser difficulty than the one the taxpayer has to…
Author: Piergiorgio Valente
This volume provides a detailed analysis of the issues of companies’ tax residence and fictitious foreign residence by offering normative, interpretative, and case-law references and assessing the impact of parent companies’ leadership and coordination activities.
The book…
Author: Piergiorgio Valente
Bilateral treaties against double taxation represent a topical theme for current and future international tax scenarios.
Within a global competitive arena, the safeguard of income flows by the Tax Authorities assumes a particularly significant role as to…
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