TRANSFER PRICING – NEW PROVISIONS ON DOCUMENTATION OBLIGATIONS

On 23 November 2020, the Director of the Italian Revenue Agency published Measure no. 360494 on transfer pricing. The above Measure of the Italian Agency implemented the provisions of art. 8 of Italian Ministerial Decree of 14 May 2018, which provided advance notice of updates to provisions on transfer pricing documentation.

The document contains instructions to replace those set out in the preceding measure (no. 2010/13765 of 29 September 2010) concerning some of the more restrictive and binding aspects. These include the obligation to prepare a Masterfile and National Documentation regardless of holding or subholding status, an increase in the data and information to be included in the Masterfile and National Documentation, and the application of an electronic signature, with time stamp, by the date of filing the income tax return.

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