International Tax Newsletter - Spring 2011 - Italy - New Transfer Pricing Rules
Law Decree nr.78 applies to Italian resident companies setting up operations with related nonresident companies. The changes are designed to reward companies that, in the eventuality of a tax audit, are in possession of supporting documents deemed appropriate to substantiate the adequacy of Group transfer pricing policies, thus avoiding the application of penalties which could range from 100% to 200% on any additional taxes being assessed.
The guidelines under this law basically introduce into domestic legislation the EU Code of Conduct on Transfer Pricing and the OECD Transfer Pricing Guidelines for Multinational Enterprises. In particular, the Tax Office must be informed about the existence of transfer pricing documentation for all open fiscal years.
For further details, Jim Alajbegu of EisnerAmper LLP in New Jersey can facilitate contact with Marco Giuliani or Walter Bonzi of MGP Studio Tributario e Societario in Italy.
International Tax Newsletter - Spring 2011
- Editor's Note
- AUSTRALIA - Taxation of Private Equity Investments
- CANADA - U.S. LLC Entitled to Benefits even under prior Treaty
- CHINA - Corporate Income Tax
- INDIA - Recent International Tax Decisions
- ITALY - New Transfer Pricing Rules
- NETHERLANDS - Selected International Tax Developments
- SINGAPORE - New DTAs and Swap Decision
- SOUTH AFRICA - International Tax Developments
- UNITED KINGDOM - DTAs and International Tax Proposals
- UNITED STATES - Key International Tax Developments