Italy - Unresolved Issues Surrounding Transfer Pricing Legislation: The Anti-Avoidance Purpose and Penalty Protection – Part 2
- A. Albano
- International Transfer Pricing Journal, 2015 (Volume 22), No 5
- 10 September 2015
This article is the second part of a contribution, and analyses the Supreme Court’s 19 December 2014 ruling in case 27087, in which – consistent with the approach considered more correct, as illustrated in the first part of this contribution – the Supreme Court recognized that transfer pricing rules do not have a specific anti-avoidance purpose.