
Italy: Transfer pricing of financial transactions – proper classification and recharacterisation risk
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine how the Italian tax authorities scrutinise financial transactions and cash pooling arrangements, with potential recharacterisation risks under transfer pricing rules
In recent years, the Italian tax administration has shown increased attention to intragroup transactions involving financial instruments – such as cash pooling arrangements and financial loans – and their proper classification.
- June 10, 2025
authors:

Carola Valente
International Liaison Manager and Strategic TP

Federico Vincenti
TP Partner