Italy - Royalties Exceeding an Arm’s Length Value: Deemed (In)applicability of “Secondary Adjustments” in Italy
- M. Manca
- European Taxation, 2019 (Volume 59), No 9
- 13 August 2019
In this article, the author discusses the legality of secondary adjustments under Italian law in respect of non-arm’s length royalty payments subject to a transfer pricing adjustment, having specific regard to the approach of the tax authorities.