The San Marino Tax Reform Proposal: the Development of the Binomial “Transparent Competitions”
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Aggressive Tax Planning: Analysis of OECD Report on Tax Governance Initiatives
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The Burden Of Proof And Transfer Pricing
This article discusses the rule on the burden of proof as laid down in Art. 2697 of the Civil Code. After an analysis, the application of this rule is examined, with an emphasis on case law concerning the burden of…
Transfer Pricing – Criminal Tax Risks under Italian Law
Transfer Pricing – Criminal Tax Risks under Italian Law The authors examine the potential criminal liability of taxpayers in the transfer pricing domain. In particular, they examine the types of criminal offences, the use of estimates regarding values, cases where…
The ‘Center of Vital Interests’: A Review of Italy’s Rules on Tax Residence
The Italian Revenue Office has been forwarding questionnaires to many individuals who, in the last five years, registered with the Register Office for Italians Residing Abroad (AIRE) and subsequently returned to Italy, because of those individuals’ financial assets and shareholders’…
2010 CFE Questionnaire on Transfer Pricing Documentation
The CFE (http://www.cfe-eutax.org/) has released a summary of the responses to the “CFE Questionnaire on Transfer Pricing Documentation”.
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01.
06
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TAX GOVERNANCE MANUAL
Author: Piergiorgio Valente
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An In-Depth Analysis of New Transfer Pricing Documentation Rules
The purpose of this work is to provide an in-depth analysis of the topic of transfer pricing documentation within the context of inter-company transactions entered into with non-resident enterprises, in view of amendments recently introduced by Decree-Law No. 78 of…