How to Avoid Italian Criminal Charges in Transfer Pricing Litigation
/Autore: Piergiorgio Valente
Practitioners should pay attention to the observations outlined below to avoid being criminally charged in cases involving transfer pricing litigation.
When Italy’s Guardia di Finanza (Revenue Guard) performs tax audits, it seizes any relevant documentation. Therefore, taxpayers should submit a written request that such documentation be read in the presence of a defense attorney in order to explain what the documents mean. If the documents mention people, those people must be allowed to testify to explain any potentially incriminating passages.
