The Transfer Pricing Implications of “Business Restructurings” from the Perspective of the Italian Tax Police

This article discusses the approach (to be) adopted by the Italian tax police in relation to the transfer pricing implications of business restructurings, as disclosed under their Circular Letter No. 1/2018, also in light of the relevant and most recent OECD Guidelines. The article includes some additional remarks as well as working examples to expand on the viewpoint of the tax police regarding cross-border restructurings.