Elena Baron – LED Taxand

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ITR TP Special Focus – Intercompany loans in Italy: Beyond the arm’s-length principle?

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TP & Business Restructuring

By Stefano Bognandi and Elena Baron2022-05-13T12:36:50+02:0013/05/2022Topics: ArticleTags: arm's-length principle, financial transactions, intercompany loans, ITC, TP

Stefano Bognandi and Elena Baron consider recent Italian case law and compliance

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Italian Transfer Pricing documentation in light of the Circular letter No. 15/E/2021

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TP & Business Restructuring

By Stefano Bognandi, Elena Baron and Umberto Stumpo2022-01-05T14:34:13+01:0014/12/2021Topics: CommentTags: public consultation, Revenue Agency, tax audit, tax measures, Transfer Pricing

On November 26th, 2021, the Italian Revenue Agency (the “IRA”) published, following the public

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Italian Transfer Pricing documentation – New measure and recent clarifications released

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TP & Business Restructuring

By Stefano Bognandi, Flavia Vespasiani and Elena Baron2021-10-05T12:20:44+02:0004/10/2021Topics: CommentTags: penalty protection regime, public consultation, Revenue Agency, tax audit, tax measures, Transfer Pricing

On September 20th, 2021, the Italian Revenue Agency (the “IRA”) released for public consultation

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Italian Supreme Court 30 June 2021 no. 18436: Profit Split is a reliable Transfer Pricing method

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TP & Business Restructuring

By Elena Baron2021-07-16T15:32:30+02:0006/07/2021Topics: Tax PillTags: IRAP, ItaCo, parent company, SubCos, Tax assessment

In 2008 and 2009 the Italian parent company of an international group («ItaCo») provided

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Italian Supreme Court 1 April 2021 no. 9075: input VAT non-deductible if the remuneration is uncertain

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Indirect Tax

By Elena Baron2021-05-13T17:31:14+02:0012/05/2021Topics: Tax PillTags: Foreign SubCo, ItaCo, Italian Supreme Court, Tax assessment, VAT

An Italian company (ItaCo) provides services to its foreign controlled company (Foreign SubCo)

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