New Provision of the Italian Revenue Agency: news regarding the transfer pricing documentation

By Gaetano Salvioli, Francesco Drago, Camilla Cominelli, Carolina Mason, Giuliana Polacco, Annarita De Carne

12-2020

On 23 November 2020, the Italian Revenue Agency published the new Administrative Provision n. 360494 (the “Provision”), endorsed in the Decree of the Ministry of Economy and Finance of 14 May 2018 (the “Decree”) which laid down new transfer pricing guidelines for the application of the arm’s length principle in compliance with the provisions set forth in article 110, paragraph 7 of the Corporate Income Tax Code (TUIR).

The Provision starts from FY 2020 and replaces the previous Administrative Provision of the Italian Revenue Agency dated 29 September 2010 on transfer pricing documentation requirements. 

In particular, the Provision provides the new regulations relating to the transfer pricing documentation and establishes the eligibility requirements of the same in order to benefit from the penalty protection regime provided for by Article 1, paragraph 6 and Article 2, paragraph 4-ter, of Legislative Decree n. 471 of 18 December 1997.

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