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New Transfer Pricing fulfilments

Starting from 2013, the OECD provided specific indications on the documentary obligations concerning transfer pricing. Art. 8 of Ministerial Decree dated 14 May 2018 provided for the alignment of the existing provisions to the international standards contained in the OECD Guidelines.

The new provisions, hereinafter the “Provvedimento”, introduce a series of innovations to the documentary requirements which taxpayers have to comply with in order to be eligible to benefit from the penalty protection regime. All taxpayers intending to benefit from the penalty protection regime will actually have to prepare a suitable Documentation including a Masterfile and a Local File.

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Overview - The Revenue Office “Provvedimento” dated 23 November 2020

By Marina Vitale - Manager of Bernoni Grant Thornton

Starting from 2013 with the BEPS project, and specifically with action 13, the OECD has provided specific indications as concerns the documentary requirements for transfer pricing; such indications have subsequently been implemented in the 2017 OECD Guidelines. [...]

 

Focus on - Transfer pricing documentation and suitability requirements

By Rossana Pieringer - Manager of Bernoni Grant Thornton

The formal and substantial innovations introduced by the Provvedimento reflect an important evolution in the Tax Authorities’ attitude towards transfer pricing, in addition to the intention of aligning the Italian documentary requirements to the most recent OECD recommendations [...]

 

Expert's opinion - Documentation for “low value-adding services”

By Valerio Palmese - Manager of Bernoni Grant Thornton

Para. 1, art. 7 of the Ministerial Decree provides for that, in order to evaluate an intercompany transaction consisting of the provision of low value-adding services, in compliance with the arm’s length principle, taxpayers are allowed to adopt a “simplified approach”. This consists in the aggregation of direct and indirect costs related to the provision of the service(s), adding a profit margin equal to 5% of said costs [...]