Penalty regime could force more unilateral rulings
December 05, 2007
Italy’s tough TP policy encourages more corporate deals. PwC reports
Italian tax authorities are taking an increasingly aggressive position in making assessments based on permanent establishment and transfer pricing issues, and that the Italian penalty system is extremely severe. In case of assessment, penalties may range from 100% to 200% of the tax increase (reduced to one fourth in case of subsequent agreement with the tax authorities). There are no specific penalty protection provisions, even if the taxpayer prepared proper transfer pricing documentation.
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.