CRA Principal, Alberto Pluviano, and co-author, Paolo de’ Capitani di Vimercate of Studio Uckmar Associazione Professionale, summarize the main lessons learned at an Italian seminar regarding national and international developments in transfer pricing. The article also outlines experiences with the following topics: transfer pricing documentation, growing competence of tax authorities, growing efficiency of tax audit activities, focus on permanent establishment, and criminal law implications.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...