Arm’s-Length Value of Royalties: Italian Case Law

Autore: Piergiorgio Valente

The international transfer pricing of goods and services between associated enterprises is regulated by article 110, paragraph 7, of the Italian Income Tax Code (TUIR), which provides that intercompany transactions can be carried out in accordance with the arm’s-length principle. In support of such provision, the Italian tax authorities issued Circulars No 32 of 1980 and No 42 of 1981, which broadly deal with transfer pricing matters. 


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