Impact of Italian Guidelines on TP Audits and APAs
/In recent years, this firm has assisted in an increasing number of tax audits related to transfer pricing matters, permanent establishment issues, and VAT fraud, among others. Considering this rise in audit activity, the Italian Tax Revenue Agency’s Circular No. 21/E that was published on June 20 2022 is a highly relevant document in providing additional guidance concerning tax audit activities for 2022.
The circular provides indications regarding:
Activities concerning audit prevention, anti-evasion, and tax litigation – making distinctions according to the type of taxpayer (large taxpayers, and medium-sized and small enterprises);
Consultancy – with particular reference to responses to appeals, legal advice, and cooperativecompliance; and
Services to taxpayers – illustrating the different types of assistance and information provided to taxpayers.
Published in: ITR (International Tax Review) - 21 December 2022
