Articles
Transfer Pricing – Criminal Tax Risks under Italian Law
/Transfer Pricing – Criminal Tax Risks under Italian Law The authors examine the potential criminal liability of taxpayers in the transfer pricing domain. In particular, they examine the types of criminal offences, the use of estimates regarding values, cases where penalties are not to be imposed, the burden of proof and who may be found criminally liable.
Tax Governance: Management of Corporate Tax Risk
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The ‘Center of Vital Interests’: A Review of Italy’s Rules on Tax Residence
/The Italian Revenue Office has been forwarding questionnaires to many individuals who, in the last five years, registered with the Register Office for Italians Residing Abroad (AIRE) and subsequently returned to Italy, because of those individuals’ financial assets and shareholders’ equity held abroad or because of income produced in foreign countries during that period. This article provides a brief description of tax residence as the ‘‘center of vital interests’’ of individuals, a concept in article 2, paragraph 2 of the Italian Income Tax Code (Testo Unico delle Imposte Dirette, or TUIR).
Potential Criminal Tax Risk in Transfer Pricing
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2010 CFE Questionnaire on Transfer Pricing Documentation
/The CFE (http://www.cfe-eutax.org/) has released a summary of the responses to the “CFE Questionnaire on Transfer Pricing Documentation”.
CCCTB: Anti-abuse Rules with Prevalence of EU Measures
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An In-Depth Analysis of New Transfer Pricing Documentation Rules
/The purpose of this work is to provide an in-depth analysis of the topic of transfer pricing documentation within the context of inter-company transactions entered into with non-resident enterprises, in view of amendments recently introduced by Decree-Law No. 78 of 31 May 2010.
