The Resource Italian Supreme Court rules on application of transfer pricing regulations

Italian Supreme Court rules on application of transfer pricing regulations

Label
Italian Supreme Court rules on application of transfer pricing regulations
Title
Italian Supreme Court rules on application of transfer pricing regulations
Creator
Subject
Language
eng
Summary
By means of Ruling No. 22010 of 25 September 2013, on the treatment of interest rates deriving from intercompany loans, Italy's Supreme Court emphasized how, for application purposes of the transfer pricing rules set forth under article 110(7) of the Italian Income Tax Code (Testo Unico delle Imposte sui Redditi, or TUIR), reference should be made to article 9 of the TUIR, which contains the factors that determine whether a transaction is at arm's length. The ruling also provides useful indications on the theme of the burden of proof; the tax authorities are exclusively required to provide evidence regarding the existence of intercompany transactions that are not at arm's length
Citation source
In: Tax notes international. - Falls Church. - Vol. 73 (2014),
http://library.link/vocab/creatorName
Valente, P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intercompany loan
  • arm's length principle
  • burden of proof
  • case law
Label
Italian Supreme Court rules on application of transfer pricing regulations
Instantiates
Publication
Label
Italian Supreme Court rules on application of transfer pricing regulations
Publication

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