The Italian Approach to Intercompany Loans
Author: Piergiorgio Valente
The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans.
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Italy: Transfer Pricing Aspects of Restructuring
Author: Piergiorgio Valente
Corporate restructuring operations and/or functional redefinition involve multinationals’ cross-border reallocation of functions, risks, assets and profit potential between/among associated enterprises.
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Transfer Pricing: New Guidelines Issued by the EU Commission
Author: Piergiorgio Valente
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Countering BEPS Through Transfer Pricing Documentation
Published in: European Taxation June 2014
In today’ s globalized economy, transfer pricing plays a key role. Over the years, as multinational corporations expanded their business at the global level, they were able to optimize their supply chain, hence increasing…
Italian Supreme Court Ruling Maintains Arm’s-length Principle Must Apply to Related Companies Within Italy
Author: Piergiorgio Valente
The Italian Supreme Court ruled, on April 16, that all transactions carried out between companies belonging to the same group, and all of which have offices in Italy, are subject to the arm’s-length principle.
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Negotiating Italy’s Arbitration Convention
Author: Piergiorgio Valente
Arbitration Convention No. EEC/90/436, approved on July 23 1990, sets forth an arbitration procedure for the settlement of double taxation issues deriving from diverging transfer pricing adjustments applied by associated enterprises in different Member States.
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EU Joint Transfer Pricing Forum: the Report on Compensating Adjustments
Author: Piergiorgio Valente
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Transfer Pricing Documentation and Country-by-Country Reporting: the OECD Discussion Draft
Author: Piergiorgio Valente
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