Transfer Pricing

Italy’s Transfer Pricing Regime and IRAP

Authors: Piergiorgio Valente, Salvatore Mattia The IRAP is Italy’s regional business tax. Established by Legislative Decree No. 446 of December 15, 1997 (the IRAP Decree), the IRAP is levied on the independent and regularly exercised activities of production or exchange…

Intercompany Financial Transactions: Valuation Aspects, Benchmarking Analysis and Critical Issues in Transfer Pricing

Author: Antonella Della Rovere and Salvatore Mattia Download (Italian)…

Transfer Pricing and Related Parties Disclosures

Author: Piergiorgio Valente To ensure the respect of the arm’s length principle, Italian Law mandates that companies’ financial statements include proper disclosures regarding transactions with related parties. Download…

Transfer Pricing: the Relation between Arm’s Length and Customs Value

Author: Piergiorgio Valente and Salvatore Mattia Download (Italian)…

Burden of Proof in Transfer Pricing: Recent Case Law

Author: Piergiorgio Valente A few decisions taken in recent years by the Italian Courts have shed some light on the allocation of the burden of proof in transfer pricing disputes. Download…

Italian Regional Production Tax and Its Impact on Taxpayers

Author: Piergiorgio Valente IRAP is a regional production tax (established by Legislative Decree No. 446 of 15 December 1997, the so-called “IRAP Decree“) levied on independent and regularly exercised activities of production or exchange of goods… Download (Italian)…

Transfer Pricing: Comparability Criteria and Benchmark Analysis

Author: Piergiorgio Valente Download (Italian)…

New Rules on “Safe Harbours”

Author: Piergiorgio Valente Download (Italian)…

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