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.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....