Piergiorgio Valente

Italy – An Outlook on the Supreme Court’s Transfer Pricing Decisions

Author: Piergiorgio Valente Transfer pricing litigation in Italy is becoming increasingly common. Notwithstanding the increasing interest in the above area, Italy has yet to establish a consolidated approach… Download…

Automatic Exchange of Information as a Tool for Fighting Tax Evasion within the EU

Author: Piergiorgio Valente and Caterina Alagna Download (Italian)…

Official Bulletin on International Tax Ruling in Italy

Author: Piergiorgio Valente On March 19 2013, the Italian Revenue Office published the second edition of the International Tax Ruling Bulletin (bulletin), about three years after its first edition (April 14 2010)… Download…

Arm’s-length Value of Royalties: Italian Case Law

Author: Piergiorgio Valente The international transfer pricing of goods and services between associated enterprises is regulated by article 110, paragraph 7, of the Italian Income Tax Code (TUIR)… Download…

Italy’s Measures Against Tax Evasion And Aggressive Tax Planning

Author: Piergiorgio Valente and Federico Vincenti The OECD suggests that the search for effective action strategies by the tax authorities goes through the introduction of incentives for the most compliant taxpayers and disincentives for those who choose to persevere with…

EU Recommendations on Aggressive Tax Planning and Tax Good Governance

Author: Piergiorgio Valente Download (Italian)…

Aggressive Tax Planning. The OECD Report “Addressing Base Erosion and Profit Shifting”

Author: Piergiorgio Valente Download (Italian)…

Comparability Analyses and Criteria for Selection: Why the Italian Tax Authorities Need More Evidence in Court

Author: Piergiorgio Valente and Federico Vincenti Transfer pricing has been the subject of a number of Italian court decisions recently with regard to the application procedure for comparability analyses with a view to an accurate reconstruction of the arm’s length…

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