Hot Topics – Transfer Pricing in Italy

Companies operating in Italy must comply with comprehensive transfer pricing documentation requirements, including the preparation of a Local File, Master File, and Country-by-Country Report in line with the OECD's guidelines and Italian tax law. Italian tax authorities place strong emphasis on the arm's length principle, scrutinising intra-group transactions such as services, royalties, financing arrangements, and tangible goods transfers. The Italian tax administration is known for its thorough transfer pricing audits, often focusing on economic substance, functional analysis, and the consistency of pricing policies. Recent developments include increased use of digital tools and data analytics to identify high-risk taxpayers, as well as a growing emphasis on transparency and documentation quality.

Dispute resolution mechanisms in Italy include Mutual Agreement Procedures (MAPs) under double tax treaties, which are actively used to resolve transfer pricing conflicts. Additionally, Advance Pricing Agreements (APAs) are available as proactive tools for achieving tax certainty, with both unilateral and bilateral APAs accessible to multinational groups.

To help companies navigate this complex environment, Deloitte Denmark is hosting a webinar featuring a transfer pricing specialist from Deloitte Italy. During the session, Giuseppe Lagrutta Partner at Deloitte Italy, will share practical insights on the local regulatory framework, guidance on documentation and risk management, and insights into recent audit trends, cases law and dispute resolution strategies.

The webinar will conclude with a live Q&A session, where you will have the opportunity to raise specific questions about transfer pricing matters in Italy.