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Questions raised on Italy’s penalty protection regime

Following Italy’s new transfer pricing (TP) requirements1 introduced on 23 November 2020, there has been much discussion as to whether the taxpayer may benefit from penalty protection that also covers additional withholding tax otherwise due when the Italian tax authorities...

New transfer pricing requirements in Italy

On 26 November 2021, the Italian tax authorities (“ITA”) issued the final version of Circular Letter no.15/E (the “Circular”), providing clarification on the new transfer pricing requirements introduced by Measure no. 360494 (“New Measure”) on 23 November 2020. This article...

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Italy

Questions raised on Italy’s penalty protection regime

New transfer pricing requirements in Italy