Books and Articles

21-05-2014 - La "reintroduzione" del transfer pricing ai fini IRAP

With the Stability Law of 2014 a new provision of law have been introduced which extends the application of transfer pricing adjustment also for IRAP tax purposes. The new rule finds application retroactively “with effect from the tax year following the year in progress at December 31st, 2007”. In the field of tax law, in order to be legitimately retroactive, a provision of law should be qualified as rules of “authentic interpretation”. In this case, however, from an analysis of the genesis of the relationships between IRAP and the rules on transfer pricing for corporate tax purposes, and from an in-depth examination of the parliamentary documents explaining the new provision, it seems that the rule cannot be qualified as a an interpretative provision. 

BELLONI M., La "reintroduzione" del transfer pricing ai fini IRAP, in Fiscalità & Commercio internazionale, n. 5, 2014, pp. 23-29.


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