Federico Vincenti

Transfer Pricing Collaborativo con Nuova Documentazione Anti-Sanzioni

In attuazione di quanto previsto dal D.M. 14 maggio 2018, l’Agenzia delle Entrate ha modificato la disciplina italiana in tema di documentazione sul transfer pricing, con effetto dal periodo d’imposta 2020. In particolare, l’Agenzia ha indicato nel Masterfile e nella…

Mutual Agreement Procedure Rules Transposed into Italian Law

With Legislative Decree No. 49/2020 published on June 10 2020, the Italian legislator approved the decree implementing EU Directive 2017/1852 on the resolution of disputes in EU tax matters. By means of this legislative decree, the rules relating to mutual…

Esterovestita anche la Società Operativa all’Estero ma con S.O. Occulta in Italia

La sentenza n. 10098/2020 della Cassazione affronta la tematica dell’esterovestizione e della stabile organizzazione occulta.Nel caso esaminato dalla Suprema Corte, l’amministratore della società “esterovestita”, ma operante in Italia, è stato accusato del reato di omessa dichiarazione ex art. 5 del…

Assessing Inter-Company Transactions and Accounting Implications during Economic Uncertainty

Inter-company financial transactions During periods of crisis, the financial sector may experience significant repercussions on transactions. The disruption to normal activity leads to a lack of liquidity and extra limits on external financing, potentially making financial transactions unprofitable. Hence, in…

Performing a Comparability Analysis during an Economic Downturn

Since December 2019, countries have witnessed the widespread impact of COVID-19 on economic activity, global value chains and profitability across most industries and geographical areas. As is the case in all periods of uncertainty, as governments try to tackle the…

Adapting Transfer Pricing Policies to Cope with COVID-19

The outbreak of COVID-19 has become one of the largest threats to the global economy and financial markets in history.In this context, the change in economic conditions has resulted in significant consequences for the transfer pricing (TP) policies adopted by…

Adapting Transfer Pricing Policies to Cope with COVID-19

The outbreak of COVID-19 has become one of the largest threats to the global economy and financial markets in history. In this context, the change in economic conditions has resulted in significant consequences for the transfer pricing (TP) policies adopted…

Evaluating TP Policies in Loss-Making Companies

During tax audits, tax authorities frequently focus on companies within multinational groups that book steady losses over several years. In these companies, behind the losses authorities often find transfer pricing policies that are not in compliance with the arm’s-length principle.…

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