GUIDA PRATICA AL TRANSFER PRICING – Comparabilità, Benchmarking, Prassi Applicativa
Authors: Piergiorgio Valente, Antonella Della Rovere, Pietro Schipani, Federico Vincenti
To order the book, click here…
15.
04
2021
A Review of Advance Tax Agreements in Italy
Advance tax agreements are binding agreements between taxpayers and the Italian Revenue Agency aimed at enhancing tax compliance and promoting the business of multinational enterprises by providing certainty on international tax issues in advance.
The arrangements are based on mutual…
Italy Amends Regulation of Advance Rulings
The 2021 Budget Law introduced significant innovations regarding advance rulings (including advance pricing agreements) provided for by Italian legislation (Article 31-ter of D.P.R. No.600/1973).
Through the instrument of advance rulings, companies with international business activities can enter into agreements with…
Italy Publishes Updated 2020 Transfer Pricing Documentation Guidance
On November 23 2020, the Italian Revenue Agency published a provision by which it amended the Italian regulation on transfer pricing documentation, making it more compliant with the OECD Transfer Pricing Guidelines.
The new measures replace those of the provision…
Mutual Agreement Procedure Rules Transposed into Italian Law
With Legislative Decree No. 49/2020 published on June 10 2020, the Italian legislator approved the decree implementing EU Directive 2017/1852 on the resolution of disputes in EU tax matters.
By means of this legislative decree, the rules relating to mutual…
Assessing Inter-Company Transactions and Accounting Implications during Economic Uncertainty
Inter-company financial transactions
During periods of crisis, the financial sector may experience significant repercussions on transactions. The disruption to normal activity leads to a lack of liquidity and extra limits on external financing, potentially making financial transactions unprofitable.
Hence, in…
Performing a Comparability Analysis during an Economic Downturn
Since December 2019, countries have witnessed the widespread impact of COVID-19 on economic activity, global value chains and profitability across most industries and geographical areas.
As is the case in all periods of uncertainty, as governments try to tackle the…
Evaluating TP Policies in Loss-Making Companies
During tax audits, tax authorities frequently focus on companies within multinational groups that book steady losses over several years. In these companies, behind the losses authorities often find transfer pricing policies that are not in compliance with the arm’s-length principle.…