Transfer pricing: An overview of the italian supreme court´s recent rulings

• Autores: Piergiorgio Valente
• Localización: Intertax, ISSN 0165-2826, Vol. 44, Nº. 6-7, 2016, págs. 564-570
• Idioma: inglés
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• Resumen

  • 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 Organisation for Economic Co-operation and Development (OECD’s) arm’s length principle.