The first two days of 71st IFA (International Fiscal Association) Congress in Rio, ending in few hours, have been focusing on the BEPS working progresses and on the future of Transfer Pricing. The outlined international scenario is getting more complex and uncertain due to the fact that 71 countries subscribed the MLI and, consequently, each bilateral agreement by adopting different implementation alternatives and many objections. Either the countries will be able to better harmonize further the...

It is necessary to clarify the correct implications deriving from the modification of paragraph 7 of article 110 of the Italian Corporate Income Tax Act (CITA) after having read several confused comments. The adoption of the arms’ length principle (instead of the fair market value) is only a formal change. On the contrary, the introduction of article 31-bis of DPR 600, which provides the rule in case of a reduction of the Italian taxable income, represents a substantial change. The results of s...

For the first time the number of existing bilateral APA with the US permit Italy to be included in the Report on APMA Program (Advance Pricing and Mutual Agreement Program). The relationship between Italy and the US are closer and closer, at least for the respective competent tax authorities. After the signature of the first bilateral APA in 2015 and the first MAP in the first quarter 2017, Italy now joins the club of countries with which the US has the highest number of procedures in place, ...

We would like to thank all our clients who sent their positive feedback to Chambers and Partners for the Europe Tax Guide – 2017 Edition, addressed Paolo Tognolo In the presentation of the Europe Tax Guide 2017, Chambers and Partners report: Paolo Tognolo, of Studio Tributario Tognolo, rises in the ranking following praise from clients, who apprecaite his expertise in international taxation and transfer pricing. Sources praises his "strong experience and deep knowledge" assessing that "he ...