A member of our team recently published a paper on Rivista di Giurisprudenza tributaria no. 3/2020, discussing a recent decision of the Milanese Tax Court concerning transfer pricing methods and tax assessments in Italy.
The paper focuses on Italian transfer pricing rules regarding the tax assessments of corporate income. In particular, Italian transfer pricing rules require the Tax Office to analyze in advance the transfer pricing method used by the taxpayer and, only after proving the unreliability of that method, they can adopt the results of a different TP method. It must, therefore, be excluded that the Tax Office can freely choose the transfer pricing method to be applied.
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