Transfer Pricing: Critical in the Remuneration of the Intangibles
/Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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Authors: Piergiorgio Valente, Federico Vincenti
In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent.
The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient grounds for an adjustment.
Author: Piergiorgio Valente, Davide Bergami, and Sophie Harding
Italy has introduced a patent box regime based on the OECD’s nexus approach, which will grant exemptions for profits derived from certain intangible assets for corporate and regional tax purposes. Italy’s alignment with the OECD should keep the usual patent box-related criticism at bay.
Author: Piergiorgio Valente
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Author: Piergiorgio Valente and Salvatore Mattia
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Author: Piergiorgio Valente
The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP).
Author: Piergiorgio Valente
The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans.
Author: Piergiorgio Valente
Corporate restructuring operations and/or functional redefinition involve multinationals’ cross-border reallocation of functions, risks, assets and profit potential between/among associated enterprises.
Published in: European Taxation June 2014
In today’ s globalized economy, transfer pricing plays a key role. Over the years, as multinational corporations expanded their business at the global level, they were able to optimize their supply chain, hence increasing their profits boosting, overall, economic growth. This has, however, also created market distortions, which have increasingly brought transfer pricing and the related policies adopted by multinational businesses to the attention of the tax authorities.
A fundamental issue in the implementation of transfer pricing regulations is asymmetry between information in the hands of taxpayers and information held by the tax authorities. This divergence makes applying and complying with the arm’ s length principle less straightforward, favouring instead the realization of aggressive tax planning scheme.
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Author: Piergiorgio Valente
The Italian Supreme Court ruled, on April 16, that all transactions carried out between companies belonging to the same group, and all of which have offices in Italy, are subject to the arm’s-length principle.
Author: Piergiorgio Valente
Arbitration Convention No. EEC/90/436, approved on July 23 1990, sets forth an arbitration procedure for the settlement of double taxation issues deriving from diverging transfer pricing adjustments applied by associated enterprises in different Member States.
Author: Piergiorgio Valente
The Italian stability law has been amended in relation to international tax ruling provisions.
Author: Piergiorgio Valente
By means of Ruling No. 22010 of September 25, 2013, on the treatment of interest rates deriving from intercompany loans, Italy’s Supreme Court emphasized how...
Author: Piergiorgio Valente
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