Studies & Updates
Strumenti operativi
Our team takes care of the privacy of the customers. For this reason we don’t indicate neither the details of the project nor the company for which it has been run. However, in this section we can summarize some significant consulting experiences performed.
Italian TP provisions update for FY 2020 onward
On November 23 2020, the Italian Revenue Agency published new official instructions (“Provvedimento”) for the preparation of Transfer Pricing Documentation in Italy, replacing the provisions of September 29 2010. In general terms the new measures, which are applicable from the 2020 tax period, make the Italian TP documentation more compliant with ...
Tightening on management fees by Italian tax inspectors, the approach of the Italian Court of Cassation in the light of recent judgments
As regards management fees, the Italian tax authorities are traditionally reluctant. Depending on the case, they may take the position that services are not rendered or that the Italian subsidiary already has its own adequate structure. Notwithstanding the above, inter-company charges for services are in principle allowed provided that taxpayers give ...
Penalty protection strengthened through the adequate transfer pricing documentation
Transfer pricing, decree issued by the Italian Ministry of Economy and Finance On May 14, 2018, the Ministry of Economy and Finance issued a decree containing the guidelines over transfer pricing guidelines (hereinafter “Decree”), published on the Official Journal (Gazzetta Ufficiale) on May 23, 2018. In detail, the Decree, referring to the ...
Offer for Assistance on Transfer Pricing Issues
In 2010, a great new opportunity has been introduced in the field of transfer pricing for taxpayers that are part of multinational groups operating in Italy. What In fact, ...
