Italy: Transfer pricing rules are revised | KPMG Belgium
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Italy: Transfer pricing rules are revised

Italy: Transfer pricing rules are revised

A law decree amending the transfer pricing rules in Italy was “converted into law” on 15 June 2017.


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Article 59 of Law Decree no. 50/2017 amends the Italian transfer pricing rules by replacing the concept of fair market value (valore normale) with a more direct reference to the arm's length criterion used in the OECD guidelines. The Ministry of Economy and Finance is expected to provide implementing rules and guidance for application of the new transfer pricing rules, by taking international “best practices” into account.

Under another provision of Article 59, a corresponding downward adjustment resulting in lower taxable income will no longer be conditional on a mutual agreement procedure (MAP), but also will be available:

  • After international audits, the results of which are shared by the cooperating countries
  • Upon receipt of an application from the taxpayer (in accordance with rules to be defined by the Italian tax authorities) following a final arm's length transfer pricing adjustment made by a country with which Italy has a tax treaty allowing an adequate exchange of information


Read a June 2017 report [PDF 183 KB] prepared by the KPMG member firm in Italy

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