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.

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.