Alessandro Valente

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners report on a decision regarding the taxation of intercompany transactions based on the activities of a branch and its parent company. Ruling No. 336, published by the Italian Revenue…

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners explore the complex relationship between Italy’s domestic tax dispute resolution mechanisms and OECD and EU directives on mutual agreement procedures. The increase in transactions between companies belonging to multinational…

Federico Vincenti and Alessandro Valente discuss the importance of DEMPE analysis and the subsequent challenges in national Courts. The article focuses also on the difficulty of both Italian Courts and Tax Authorities in implementing the OECD TP principles with reference…

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…

On September 20 2021, the Italian Revenue Agency (IRA) published the draft circular letter (the Circular) aimed at providing a vast range of clarifications on the transfer pricing (TP) documentation’s legal framework. The Circular has been drafted to provide further…

In early 2021, two decisions of the Italian Supreme Court dealt with the issue of certain inter-company transactions that were not performed according to the arm’s-length principle due to the existence of an overall advantage for the multinational group. Published…