Transfer Pricing: 'Broad-Based' Control Concept Pursuant to Italian Courts
/Published in: TP Week, May 25, 2016
Article 110, paragraph 7 of the TUIR (i.e., Italian Income Tax Code, hereinafter, “TUIR”), related to the Italian Transfer Pricing regime, establishes that in order for the above rule to be applicable, one of the companies involved in the intercompany transaction must exercise control over another company, or that both be under common control.
