On November 26th, 2021, the Italian Revenue Agency (the “IRA”) published, following the public consultation time frame, the Circular Letter no. 15/E (the “Circular”) providing clarifications on transfer pricing documentation (the “TP Documentation”) rules contained in the Administrative Provision n. 360494 of November 23rd, 2020 (the “Provision”).

Italian taxpayers may opt to prepare TP Documentation to benefit of the penalty protection regime in the event of a tax assessment. In the absence, penalties for unfaithful tax return (from 90% to 180% of the higher due taxes) become applicable.

Below we provide a comprehensive view on Italian TP Documentation rules in the light of the above Circular, hoping that the existing uncertainties will be further clarified in the near future.

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