The Resource Transfer pricing : an overview of the Italian Supreme Court's recent rulings

Transfer pricing : an overview of the Italian Supreme Court's recent rulings

Label
Transfer pricing : an overview of the Italian Supreme Court's recent rulings
Title
Transfer pricing : an overview of the Italian Supreme Court's recent rulings
Creator
Subject
Language
eng
Summary
Rulings on transfer pricing matters issued in the last few years by Italian Courts covered various themes. Among these, the Tax Authorities frequently challenged the selection and application of transfer pricing methods, comparability analyses developed by taxpayers supporting intercompany policies, the analysis of special transactions such as intercompany loans and services as well as transactions related to intangibles. The lack of a frame of reference, on the one hand, and the (perceived) uncertainty of the subject, on the other hand, engendered difficulties as to the crafting of a uniform jurisprudential orientation, leading judges oftentimes to settle disputes through a line of reasoning, not always consistent with the OECD's arm's length principle
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 44 (2016), no. 6&7 ; p. 564-570
http://library.link/vocab/creatorName
Valente, P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • case law
  • intercompany loan
  • transfer pricing adjustment
  • intangibles
  • burden of proof
  • documentation requirements
  • arm's length principle
Label
Transfer pricing : an overview of the Italian Supreme Court's recent rulings
Instantiates
Publication
Label
Transfer pricing : an overview of the Italian Supreme Court's recent rulings
Publication

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