Author: Piergiorgio Valente
The last decade saw a significant increase of transfer pricing controversies as well as assessments issued by the tax authorities by virtue of the application of Article 110, Paragraph 7, of the TUIR..
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Author: Piergiorgio Valente
The “Transfer Pricing Manual” (II Edition, pp. 3400) is a helpful tool that provides professionals and scholars with accurate and rigorous answers – from both, a legal-economic perspective as well as a hands-on approach – on complex…
Author: Piergiorgio Valente
A tool for settling transfer pricing controversies is the EU Arbitration Convention No. 90/436/EEC. If a double taxation in transfer pricing occurs, the enterprise may submit its case to the competent authority of the state in which…