In Memoriam of Giuseppe Barranco Di Valdivieso

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It is with deep sadness that the CFE Tax Advisers Europe Executive Board Members and CFE Office Team join together in paying their respects to the late Giuseppe Barranco Di Valdivieso.

Giuseppe Barranco Di Valdivieso’s contributions to CFE Tax Advisers Europe during his 20 years of dedicated and selfless service were many and varied. Giuseppe was truly beloved by everyone who worked with him. He was a visionary leader, a person fascinated by big ideas and a lifelong friend to many. The enthusiasm and passion he put in his work and collaboration with CFE and his presence will be deeply missed.

The President and Executive Board of CFE Tax Advisers Europe take this opportunity to extend their deepest and most sincere condolences to Giuseppe Barranco Di Valdivieso’s family and loved ones, in the hope that his dear memory will bring comfort to all.

May his soul rest forever in perfect peace.

TP Liabilities on Criminal Tax in Italy: Assessing, Adopting and Avoiding

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During the course of tax audits, Italian tax authorities often challenge the value of the goods or services subject to intra-group relationships.
These disputes are particularly relevant for the Italian entity/company that carries out such inter-company transactions.
Should there be no coincidence between the declared assessments and the assessments made - based on Article 9 Testo unico delle imposte sui redditi (TUIR) - potential liability scenarios related to the crime of unfaithful declaration could open up.

Published in: International Tax Review (ITR) - 15 April 2020

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Taxing the Digital Economy: a Realistic Goal for 2020?

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An ambitious project.
New year. New resolutions.

From an international taxation perspective, the resolution to reach in 2020 is a clear and an urgent one: worldwide consensus on how to tax the digital economy. lt is all but a new project, considering that the discussion started 5 years ago. But 2020 has been set as the landmark-deadline year to find a common solution. lndeed, there is no more margin and no excuse for extensions.

Published in: 47th Issue IAFEI Quarterly

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Adapting Transfer Pricing Policies to Cope with COVID-19

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The outbreak of COVID-19 has become one of the largest threats to the global economy and financial markets in history.
In this context, the change in economic conditions has resulted in significant consequences for the transfer pricing (TP) policies adopted by multinational groups, which are forced to promptly adapt their business models.
This rationale appears to be even more relevant in a globalised world where recessionary circumstances affecting a single country or a single market, spiral to generate an unforeseen amount of consequences at a global level.

Published in: International Tax Review (ITR) - 26 March 2020

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Italy Issues Changes to the Operation of Country-by-Country Reporting

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The Ministry of Economy and Finance has produced some amendments regarding the use of the data and information contained in country-by-country reporting (CbCR) with the Ministerial Decree no. 194 of August 8 2019 (hereinafter, the Decree). Pursuant to Article 4 of the Decree of February 23 2017, the information contained in CbCR concerns consolidated data relating to all the companies of the group analysed regarding revenues, profits, taxes, etc., as well as the definition of all the activities and functions carried out by the group’s entities.

Published in: www.itrinsight.com (Local Insights) - January 2020

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Strategic Partnership with European Parliament

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In October 2019, CFE Tax Advisers Europe celebrated its 60th Anniversary under the high patronage of the European Parliament, with a series of events, including a General Assembly, the inaugural Global Tax Advisers Platform conference and technical committee meetings held in Torino, Italy, on 3 and 4 October 2019, hosted by the Italian member organisations of CFE - Associazione Nazionale Tributaristi Italiani (ANTI) & Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili (CNDCEC).
The CFE Tax Advisers Europe was honoured to receive the patronage of the European Parliament of its 60th Anniversary, confirming the close links between the objectives of CFE’s initiatives and the values of the European Union.

Published in: Living CFE - Tax Advisers Europe - July/December 2019

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Advance Pricing Arrangements: Optimal Tool – Optimal Framework?

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Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation to the tax impact of their cross-border activities through an agreement with a tax administration in advance of such activities. APAs can be unilateral, bilateral, or multilateral depending on the number of national tax administrations involved, the latter two promising that the agreement made shall not be questioned in the other affected tax jurisdiction.

Departing from the enhanced mutual agreement procedure (MAP) framework recently established among Member States through the Tax Dispute Resolution Directive, a future EU legislative initiative could outline a robust framework for MAP APAs in the Single Market.

Published in: INTERTAX, Volume 48, Issue - January 22 2020

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Taxation in the Future – A New EU: Vision and Impact

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The Change of Scenery

On 1 December 2019, the von der Leyen Commission took over for the coming 5 years, and it is called to deliver on a most challenging mandate. The European identity is questioned more than ever before, with Brexit being just one of the several signs. The established structures of the EU and global economy are also questioned. Unprecedented technological developments threaten with unemployment millions of people and demand rapid evolution of new skills, while promising widespread prosperity and unknown potential for humankind. Digitalization keeps alleviating cultural differences; at the same time though, nationalist movements are getting stronger and stronger. Climate change is present, undeniable reality, already in the process to overhaul the face of our planet.

Published in: Kluwer International Tax Blog - December 16, 2019

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Evaluating TP Policies in Loss-Making Companies

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During tax audits, tax authorities frequently focus on companies within multinational groups that book steady losses over several years. In these companies, behind the losses authorities often find transfer pricing policies that are not in compliance with the arm’s-length principle. This observation is supported by the 2017 OECD Transfer Pricing Guidelines 2017 (para 1.129 – 1.131).

According to the OECD Guidelines, when a company that belongs to a multinational group consistently books losses while its multinational parent remains profitable, authorities must analyse its tax practices, paying particular attention to the TP policies.

Published in: ITR - International Tax Review - 05 December 2019

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Italy Amends its Patent Box Regulation

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The patent box regime was introduced in Italy with the Legge di Stabilità 2015 and has been subject to amendments over subsequent years. The aim of this regime is to provide for tax relief on income deriving from intangible assets like industrial patent and intellectual property designs and models.

The original regulation provided for the obligation to undergo a ruling procedure by the Italian tax authority to identify methods of determining the qualified income deriving from the direct use of intangible assets (in the case of indirect use of intangible assets, this ruling was not mandatory).

Published in: ITR - International Tax Review - 30 October 2019

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Let's Meet in Matera and Celebrate IAFEI's 50th Anniversary

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In the year in which IAFEI celebrates its 50th anniversary, the 49th Congress of IAFEI will take place in Italy in Matera (2019 European capital of culture) on October 25th and 26th.
The main topic is quite inviting: “An holistic view of the enterprise in a changing world - Cultural heritage, basic value and forward guidance for driving change in business and growth models“.
The scope is to discuss how shall the today’s enterprises evolve towards the one of the future.

Published in: 45th Issue IAFEI Quarterly - 1 October 2019

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Mobility Monday’s - Transfer Pricing, How Costs of Employees is Born and Cross Charged

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Tax issues and global mobility go hand in hand. There can be tax matters for the employee and for the employer. The corporate tax implications (tax matters that relate to the employer entities) are generally less well understood in the world of Mobility/HR, than the payroll and employee and employer issues.

Within the corporate tax area is transfer pricing. In the context of employee mobility, this is an area that concerns itself with how the cost of employees is borne and cross charged within a group. Mobility often has to work in partnership with finance and tax departments around this issue.

Published in: Mobility Mondays - Crowe UK

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Blockchain Technology: Driving Towards the Next Industrial Revolution?

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New technologies have provoked a new revolution in human history: the so-called “digital revolution” or “next production revolution”. It marks the passage from the mechanical or analogue electronic technology to digital electronic technology, with primary impact on the area of communication but also, subsequently, in production.
It is revolution, because it has the capacity to overhaul established social structures.
In fact, it is already doing so: starting with business and trade, new technologies are now shaping labour, governance, culture.
The dominant trend is towards a global village: everyone and everything is a few steps – or rather a few clicks – away; cultures intermingle in an explosive mix, while national borders keep losing ground and relevance – mere remnants of a fading past.
This is where we are heading and each new development, e.g. every new platform, novel application, promising social network or innovative robot is one more (cyber-) brick for the construction of the global village.

Published in: Legal Perspective on Blockchain - Theory, Outcomes, and Outlooks

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Prof. Paolo Centore

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I am deeply touched by the death of Professor Paolo Centore. He was a very good friend and a devoted professional.

I lost a most loyal and kind colleague and I would like to share the sorrow of his immediate family.

We will remember him as an enthusiastic tax consultant and an excellent promoter of tax cooperation in CFE Tax Advisers Europe.

May his soul find rest in perfect peace!

With deep regards

Piergiorgio