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Italian Revenue Agency Issues Clarifications On Arm’s-Length Range

Federico Vincenti and Alessandro Valente of Valente Associati GEB Partners/Crowe Valente explain how Circular Letter No. 16/E will affect transfer pricing (TP) calculation in Italy.
On May 24 2022, the Italian Revenue Agency published Circular Letter No. 16/E (referred to hereafter as the Circular), clarifying the correct definition of the arm’s-length range for TP purposes.
The arm’s-length range concept was covered in Article 6 of the Decree of the Italian Ministry of Economy and Finance, dated May 14 2018 (hereafter referred to as the Decree).

Published in: ITR (International Tax Review) – 20 July 2022

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