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.
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.
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
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