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.
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...