Both Italy and France finalized their transfer pricing documentation regulations by issuing administrative instructions on, respectively, December 15, and December 23, 2010. The two countries’ regulations differ quite significantly despite the fact that both are explicitly inspired by the European Union Code of Conduct on transfer pricing documentation. This article provides a comparative review of some of the key features of each set of regulations.
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...