Italy - State of Play of Intra-Group Financing Arrangements
- R. D'Angelo
- International Transfer Pricing Journal, 2017 (Volume 24), No 4
- 19 July 2017
The author provides an overview of intra-group financing arrangements from a corporate, tax and accounting perspective. It also discusses the treatment of interest-free loans from the perspective of both the tax authorities and the Supreme Court and considers the characterization by Italian courts of cash pooling arrangements – including their possible recasting as intra-group loans.