The Resource Transfer pricing audits : position of the Italian courts

Transfer pricing audits : position of the Italian courts

Label
Transfer pricing audits : position of the Italian courts
Title
Transfer pricing audits : position of the Italian courts
Creator
Subject
Language
eng
Summary
The Italian Tax Authorities encounter difficulties in supporting their own transfer pricing audits in an unassailable manner, which is by no means a lesser difficulty than the one the taxpayer has to face when having to structure its own transfer pricing policy, especially if its intention is to adopt traditional methods. With reference to the application of the cost-plus mark-up method, the Italian Courts rejected the Tax Authorities' assessments on the basis that comparability was not absolute. Even when the Tax Authorities - with regard to differences of functions and risks - extensively debated on their irrelevance for the purpose of determining the price, the Judges ultimately ascertained an inadequate motivation for such position
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 41 (2013),
http://library.link/vocab/creatorName
Valente, P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • interest
  • royalties
  • management fee
Label
Transfer pricing audits : position of the Italian courts
Instantiates
Publication
Label
Transfer pricing audits : position of the Italian courts
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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