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Italy: Draft transfer pricing regulations released for public consultation

Italy: Draft transfer pricing regulations released

The Italian Ministry of Finance on 21 February 2018 released draft rules under a framework for implementing the base erosion and profit shifting (BEPS) Actions 8-10 that include transfer pricing guidelines.


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The draft transfer pricing regulations are available on the Finance Ministry website (Italian) and are made available for public consultation and comments until 21 March 2018. 

Draft transfer pricing regulations

The draft transfer pricing regulations include proposals for the following:

  • Guidelines for use of the “arm’s length principle” with respect to inter-company transactions following BEPS changes (as per art. 110.7 of DPR 917/1986)
  • Procedures for Italian voluntary, unilateral downward adjustments that can be claimed by Italian taxpayers following the finalization of transfer pricing assessments by a country or jurisdiction with which Italy has an income tax treaty that allows for the appropriate exchange of information (as per art. 31quater 1.c of DPR 600/1973)

Along with the draft regulations, the Ministry of Finance also published an Italian language translation of the OECD transfer pricing guidelines.


Read a February 2018 report [PDF 318 KB] prepared by the KPMG member firm in Italy


For more information, contact a tax professional in Italy: 

Gianni De Robertis | +39 06 80963 563 |

Eugenio Graziani | +39 045 8114 344 |

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