Pricing: implementation of Article 31-quater of the Presidential Decree no. 600/1973

On 30 May 2018, the Italian Tax Authorities issued the implementation of the new Italian rules provided for in Article 31-quater, paragraph 1, letter c, of the Presidential Decree no. 600/1973. In particular, the Italian Tax Authorities set out the implementation rules for the procedure to be started in order to obtain a tax adjustment from the taxable corporate income in Italy, in case of a tax issue definitively assessed by a foreign Country in accordance with the arm’s le...
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Italy complies with OECD guidelines by updating the transfer pricing national rules

After the conclusion of the works on the Public Consultation on Transfer Pricing, yesterday, the Ministry of Economy and Finance signed the Decree containing the guidelines for the implementation of the Italian Transfer Pricing rules according to Article 110 of the Italian Income Tax Code. The Ministerial Decree implements the amendments to Article 110 of the Italian Income Tax Code, introduced by Decree Law 50/2017, based on which cross-border transactions between associated companies have t...
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Transfer Pricing Consultation: 08.05.18 meeting

A meeting was held yesterday, at the Ministry of Economy and Finance, to discuss about the comments and contributions sent to the Authorities, for the Public Consultation on transfer pricing (TP). The participants in the event analyzed the proposal of change for the Measure schemes, published on the MEF website in February 2018, mainly concerning the following topics: the regulation of transfer pricing of low value adding intra-group services; the latest news on the requirements of th...
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A Public Consultation on Transfer Pricing is opened

The Ministry of Economy and Finance, together with the Revenue Agency and the Financial Police, have opened a public consultation on transfer pricing, on the implementation of the provisions of Article 110, paragraph 7 of the TUIR and of article 31-quater of the Decree n. 600 of 1973. The project will focus on the following documents: - Scheme of the ministerial decree referred to paragraph 7 of article 110 of the TUIR - Scheme of the measure provided for in article 31-quater of the D.P.R. n....
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Studio Tributario Tognolo celebrates 15 years!!!

Studio Tributario Tognolo organized a seminar to celebrate 15 years from its foundation: POST BEPS ERA: implementation, opportunities and critical issues The event focused on the state of implementation of the Actions taken by OECD and G20 to contrast the BEPS, in a renewed international context/scenario. Eminent speakers contributed to the discussion:  Alessandro Denaro, representing the European Commission point of view, illustrated on the role of the tax regimes adopted by the States an...
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OECD releases further guidance on Country-by-Country reporting (BEPS Action 13)

CBCR and appropriate use of information The OECD's Inclusive Framework on BEPS has updated the existing guidance on the implementation of CbC Reporting that now addresses the following issues: the definition of revenues; the treatment of MNE groups with a short accounting period; and the treatment of the amount of income tax accrued and income tax paid. OECD has also realized a new guidance on the meaning of "appropriate use" of the information contained in CbC Reports, the conseq...
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