Italian Supreme Court Rules TP Irregularities Must Be Substantiated with Clear Avoidance Behaviour

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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.

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Italy’s Patent Box Regime Should Escape Criticism Because of Alignment with OECD Nexus Approach

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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.

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