New Transfer Pricing Documentation Requirements in Italy: The Renewed Interplay between Domestic Regulations and International Sources

Abstract

On 23 November 2020, the Italian tax authorities issued the new Operational Instructions on transfer pricing documentation, applicable already for fiscal year 2020. The new operational instructions are aligned with domestic and international sources on transfer pricing documentation, specifically the OECD Guidelines. Taxpayers and tax consultants will need to carefully check that their documentation is in line with the new instructions with regard to the changes from the previous regime stemming from 2010.