Transfer Pricing Year-end Adjustments
/Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente and Caterina Alagna
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente and Caterina Alagna
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente
In matters of transfer pricing, the terms “compensating adjustments” and “year-end adjustments” refer to the adjustments made by companies to align the transfer pricing criteria...
Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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Published in: Intertax - Volume 41 January 2013
The Italian Tax Authorities encounter difficulties in supporting their own transfer pricing audits in an unassailable manner, which is by no means a lesser difficulty than the one the taxpayer has to face when having to structure its own transfer pricing policy, especially if its intention is to adopt traditional methods.
With reference to the application of the cost-plus mark-up method, the Italian Courts rejected the Tax Authorities’ assessments on the basis that comparability was not absolute. Even when the Tax Authorities – with regard to differences of functions and risks – extensively debated on their irrelevance for the purpose of determining the price, the Judges ultimately ascertained an inadequate motivation for such position.
Author: Ivo Caraccioli
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Author: Salvatore Mattia and Caterina Alagna
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Author: Piergiorgio Valente
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Author: Piergiorgio Valente
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