Italian Taxation of Corporate Residence Transfers

/

Author: Piergiorgio Valente

The decision to transfer an enterprise’s corporate seat abroad generally includes a thorough assessment of several tax and civil law issues. The possibility for the source country to lose its tax sovereignty has led governments to introduce exit tax regimes, but these regimes have been deemed by the Court of Justice of the European Union to be incompatible with EU rules.

Download

Countering BEPS Through Transfer Pricing Documentation

/

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.

Download