Serious Penalties under Arbitration Convention No 90/436/CEE. Criminal Aspects and Sanctions in Italian Legal System
Authors: Piergiorgio Valente and Ivo Caraccioli
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Transfer Pricing in Developing Countries: The UN Manual
Author: Piergiorgio Valente
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Open Debate on the Tax Governance
Author: Piergiorgio Valente
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Italy’s CFC Regime: Wholly Artificial Arrangements
Author: Piergiorgio Valente
In Italy the subject of controlled foreign corporations is extremely topical. The Italian Revenue Office issued Circular 51/E of October 6, 2010 (the circular)…
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OECD Model: is the Distributor Personal Permanent Establishment?
Author: Piergiorgio Valente
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Monti Decree: News on “Shielded” Assets and Property Held Abroad
Author: Piergiorgio Valente e Salvatore Mattia
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Arbitration Convention 90/436/EEC: Inapplicability in Case of Serious Penalties
Author: Piergiorgio Valente
A tool for settling transfer pricing controversies is the EU Arbitration Convention No. 90/436/EEC. If a double taxation in transfer pricing occurs, the enterprise may submit its case to the competent authority of the state in which…
Theoretical and Substantial Suitability for the Non-Application of Sanctions in Transfer Pricing
Authors: Piergiorgio Valente e Roberto Betti
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