Royalties Exceeding an Arm’s Length Value: Deemed (In)applicability of “Secondary Adjustments” in Italy

Journal
Manca, M.
Italy
European Taxation 2019 (Volume 59), No. 9
PriceUSD 45

In this article, the author discusses the legality of secondary adjustments under Italian law in respect of non-arm’s length royalty payments subject to a transfer pricing adjustment, having specific regard to the approach of the tax authorities.