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The Italian Supreme Court rules on preferring the “internal CUP method” over the “external CUP method”

Don’t miss the new article on International Tax Review: The Italian Supreme Court has issued a key ruling, establishing that the internal CUP method is preferable to the external CUP method in transfer pricing analyses. Discover the implications of this…

Black list costs, crypto-assets and permanent establishment: new rules to encourage investments (and guarantee taxation)

The 2023 Budget Law introduces tax innovations to attract investments and guarantee taxation:Costs from non-cooperative countries: deductible within the normal value, unless proof of economic interest.Investment Management Exemption: avoids the creation of permanent establishments for foreign investment vehicles.Crypto-assets: capital gains…

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