Transfer Pricing

Transfer pricing and the Ford Italia case

Author: Piergiorgio Valente The last decade saw a significant increase of transfer pricing controversies as well as assessments issued by the tax authorities by virtue of the application of Article 110, Paragraph 7, of the TUIR.. Download…

01. 05

2012

TRANSFER PRICING MANUAL (2nd Ed.)

Author: Piergiorgio Valente The “Transfer Pricing Manual” (II Edition, pp. 3400) is a helpful tool that provides professionals and scholars with accurate and rigorous answers – from both, a legal-economic perspective as well as a hands-on approach – on complex…

Transfer Pricing in Developing Countries: The UN Manual

Author: Piergiorgio Valente Download (Italian)…

(Ir)relevance of Irap and VAT in Case of Transfer Pricing Adjustments

Authors: Salvatore Mattia e Claudio Melillo Download (Italian)…

Andaf: White Paper on Simplification. The Contribution of the Tax Technical Committee

Author: Salvatore Mattia Download (Italian)…

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 Download (Italian)…

Italy and the Transfer Pricing Issue

Author: Piergiorgio Valente Transfer pricing is the hot topic in the tax audit world right now in Italy says Piergiorgio Valente, managing partner of law firm Valente Associati GEB Partners… Download…

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