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Italy Amends Regulation of Advance Rulings

The 2021 Budget Law introduced significant innovations regarding advance rulings (including advance pricing agreements) provided for by Italian legislation (Article 31-ter of D.P.R. No.600/1973).
Through the instrument of advance rulings, companies with international business activities can enter into agreements with the Italian tax authorities, in relation to the following instances:

a) Prior definition of the transfer pricing methods applicable in intercompany transactions;
b) Exit or entry values in the event of transfer of residence;
c) Attribution of profits and losses to the permanent establishment in another country of a company resident in Italy or to the permanent establishment in Italy of a non-resident entity;
d) Prior assessment of the existence or otherwise of the requirements for a permanent establishment situated in Italy; and
e) Application to a concrete case of rules, also of conventional origin, concerning the payment or receipt of dividends, interest and royalties and other income components to or from non-resident parties.

Published in: ITR (International Tax Review) – 3 February 2021

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