Autore: Piergiorgio Valente

By means of Ruling No. 22010 of September 25, 2013, on the treatment of interest rates deriving from intercompany loans, Italy’s Supreme Court emphasized how, for application purposes of the transfer pricing rules set forth under article 110(7) of the Italian Income Tax Code (Testo Unico delle Imposte sui Redditi, or TUIR), reference should be made to article 9 of the TUIR, which contains the factors that determine whether a transaction is at arm’s length.