Transfer Pricing
Country Summary

This document provides an overview of Italy’s transfer pricing regulations, focusing on the adoption of BEPS Action 13 guidelines. It outlines key aspects of Italian transfer pricing laws, including definitions of related parties, documentation requirements, and advance pricing agreements (APAs). The document also discusses the criteria for country-by-country reporting and the use of transfer pricing methods. Italy’s stance on tax havens and blacklists, along with audit practices, is explained. It concludes with information about penalties, record-keeping, and compliance. Italy aligns itself with international standards, emphasizing transparency and documentation to guide multinational enterprises (MNEs).


Italy’s Transfer Pricing Regulations

Italy has well-established transfer pricing regulations that align with the OECD Guidelines.

Definition of Related Party

Defining Related Parties

In Italy, related parties are defined according to OECD standards. This means that transactions between entities with certain affiliations are subject to transfer pricing regulations.

Nature of Transfer Pricing Documentation

Nature of Transfer Pricing Documentation

Italy’s approach to transfer pricing documentation adheres to international standards and is consistent with the OECD Guidelines.

Tax Havens & Blacklists

Tax Havens and Blacklists

Italy maintains a list of countries and territories considered as tax havens. Transactions with entities in these locations receive heightened scrutiny.

Advance Pricing Agreements (APAs)

Advance Pricing Agreements (APAs)

Italy offers Advance Pricing Agreements, allowing companies to seek pre-approval for their transfer pricing methodologies, providing greater tax certainty.

Audit Practice

Transfer Pricing Audits

Italian tax authorities conduct audits to ensure transfer pricing compliance. Companies should maintain comprehensive documentation to support their pricing strategies.

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