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.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...