Italy Updates Transfer Pricing Rules And Patent Box Regime

Italy publishes Decree n. 50 that implements changes to its transfer pricing and patent box regime, including arm’s length principle and updated list of intellectual property, MNE Tax Reported.

Arm's Length Principle

Decree n. 50 implements a transfer pricing method that is in line with the OECD’s arm’s length principle. The article 110, paragraph 7, of the new corporate tax act, allows tax authorities to make transfer pricing adjustments if the operations between related parties are not in line with conditions and prices that would have been made between the parties that are not related. The price for a transaction is therefore what the price of that transaction would be on the open market. The law states that the Ministry of Finance may issue regulations to set up best practices, MNE Tax informed.

Italy transfer pricing

The new law also allows corresponding adjustments following a transfer pricing adjustment that results in a decrease in taxable income. The list of intellectual property in the patent box regime will include software protected by copyright; industrial patents; business, commercial, design models that are capable of legal of legal protection; and industrial and scientific information and know-how that is secret and capable of legal protection. For full insight, see MNE Tax.

Source: MNE Tax



We Provide Solutions - Let's Talk Business!

CFO's Journey From 'Staying Out Of Trouble' To Being 'Fully In Control'

TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):

Roadmap for CFO's


Implementation of BEPS Action 13 - Argentina, Mexico and other countries of Central America
Tuesday, 12 December, 2017 | 5:00 PM - 6:00 PM (CET)
Tuesday, 11 January, 2018 | 5:00 PM - 6:00 PM (CET)

Mapping the Trends in MAP Resolution of Tax Treaty Disputes after BEPS
Thursday, January 18, 2018 | 04:00 PM - 05:00 PM (CET)

Copyright © 2017
Transfer Pricing Associates BV.
All rights reserved.

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530