New Legislation on TP Documentation

View this page in: Italiano

In accordance with the Italian legislation on transfer pricing documentation introduced earlier this year (Law Decree no 78 dated 31 May 2010 definitively converted into law on 30 July), the Italian Tax Authorities have now as of 29 September issued a detailed Regulation covering the form that transfer pricing documentation should take for companies and permanent establishments.
Although documentation is not mandatory, the Regulation indicates that the tax authorities will consider whether a company has communicated the existence of such documentation in making its risk assessment. Appropriate documentation also protects against tax geared penalties. Such protection can apply to past open years if the taxpayer notifies possession of the documentation within the short time limits specified. This is 90 days from 29 September, with potential for extension in certain cases as described below.


Our services

  • Transfer Policy Documentation Check Up
  • Support to the Board on the integration/predisposition of the document package
  • Economic analysis and TP policy improvement

Why PwC?

PwC Italy is able to bring to its clients access to local and international teams comprising industry experts who combine industry specialist knowledge with transfer pricing.
PwC‘s global transfer pricing network has developed a range of proprietary tools which help them to share knowledge, which facilitate project management and which provide access to the best available data sources for comparables and other economic analysis.
PwC Italy has an international team of in-house specialists, which offers both wide ranging understanding of the legal and practical aspects of transfer pricing across the world together with practical hands-on experience of the Italian environment and international best practice.
PwC Italy can offer its clients operational support throughout all the various phases of the project.