Transfer pricing documentation – the changes introduced by the new measure

The process of aligning national transfer pricing provisions with OECD standards and, in particular, with Action 13 of the BEPS project and the OECD Guidelines published in July 2017 (“OECD Guidelines“) continues.

The Revenue Agency, with the measure n. 360494 of 23 November 2020, implementing the provisions of the D.M. 14 May 2018 (“MEF Decree”), updated the provisions on transfer pricing documentation to be observed by taxpayers to benefit from the penalty protection regime.

The new provisions replace those laid down by the previous measure n. prot. 2010/137654 of 29 September 2010 and will be effective starting from the financial year in progress at the date of the publication, i.e. from 2020 for companies whose financial year corresponds to the calendar year.