Transfer Pricing and Double Taxation: Italy's Downward Adjustment Procedure

The new rules (regulation - Provvedimento 108954/2018) were issued on 30 May 2018, following a public consultation launched in February 2018.

The new regulation follows the amendments introduced in 2017 for Italian transfer pricing rules.

Such amendments provided for an extended taxpayer’s right to request downward adjustment in connection with the correct application of the arm’s-length principle.

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