Deduction of costs arising from transactions with entities domiciled in low-tax jurisdictions requires proof of specific economic interest.
economic substance
Burden of Proof of Tax Avoidance on Tax Administration, Italian Supreme Court Says
By Marco Rossi on
The Tax Section of the Italian Supreme Court in its judgment n. 1465 of January 21, 2009 held that the tax administration bears the burden to prove that a transaction is carried out solely to obtain a tax advantage, in order to disregard the transaction and deny the tax benefits obtained by the taxpayer under…