By the first deadline of December 28, 2010 1,300 Italian taxpayers filed the transfer pricing documentation notice. Of them 500 come from foreign enterprises with Italian business operation. Transfer pricing documentation filing protects from penalties in case of audit and transfer pricing adjustments.
Continue Reading Update on Italian Transfer Pricing Documentation Filing

Italy issued circular 58/E with guidance on transfer pricing documentation for multinational companies. The tax administration clarified that failure to file the transfer pricing documentation notice may be considered as a factor to select taxpayer that will be subject to audit
Continue Reading Italy’s Tax Administration Issued Guidance on Transfer Pricing Documentation

Italy issued ruling implementing transfer pricing documentation requirements. Italian transfer pricing documentation framework largely mirrors the EU transfer pricing documentation of conduct and OECD Guidelines. Strict deadlines apply to transfer pricing documentation for 2010 and prior years. Compliance with new transfer pricing documentation requirements allows protection from penalties.
Continue Reading Italy Enacted Rules on Trasfer Pricing Documentation

A decree presented to the Italian Council of Ministers today will introduce new provisions on contemporaneous documentation for transfer pricing purposes and a new black list with a duty to disclose any transaction carried out in or with any black listed countries to the tax administration. Also, the minimum threshold for the duty to report cross border transfers of money will be reduced to euro 5,000.
Continue Reading Italy’s Government to Approve New Rules on Transfer Pricing Documentation, Anti Tax Abuse

The European Court of Justice with its decision in case C-285/07 held that the double carryover basis requirement imposed under German law to accord tax free treatment to the shareholders of the target corporation in a EU cross-border transfer of shares violates the EU mergers directive and EC law.
Continue Reading ECJ Ruled That Restriction to Tax-Free Treatment of Cross-Border Transfer of Shares is Illegal