Tax Focus on Advanced Pricing Agreements in Italy

Published

Nov 25 2020

Written By

Partner
Italy

I am an international tax lawyer, focusing on tax disputes, with almost 30 years of experience working for multinational groups.

Francesco Drago

Associate
Italy

I'm a tax advisor working in the Italian tax team. I specialise in transfer pricing, providing consultancy and assistance to multinational clients in relation to a wide range of international tax issues.

Practices

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Italy

APAs are now well known to Italian companies belonging to multinational groups, which intended (or intend) to agree on the correct remuneration of intra-group transactions with the Revenue Agency, in order to avoid tax audits, assessments, and lengthy tax litigation. It is a way to mitigate conflicts between taxpayers and tax authorities.

Current legislation provides regulations relating to the procedure for unilateral APAs concluded between the Revenue Agency and the entities present in Italy. If the APA also involves tax authorities of one or more States (so called bilateral or multilateral agreements), the procedure followed is that provided for by International Conventions against Double Taxation (art. 31-ter of Presidential Decree no. 600 of 29 September 1973).

The 2021 Budget Law (see art. 1, par. 1101, Law n. 178/2020) introduced some relevant changes to the current APA regulations.

Read the alert here >