Unresolved Issues Surrounding Transfer Pricing Legislation: The Anti-Avoidance Purpose and Penalty Protection – Part 1

Journal
Albano, A.
Italy
International Transfer Pricing Journal 2015 (Volume 22), No. 1
PriceUSD 45

This article, the first of a series of two, presents the results of research based on trends observed in Italian tax audits which focus more and more on transfer pricing issues when dealing with MNEs. Recent decisions by the Supreme Court are also discussed.