New transfer pricing documentation requirements in Italy
WTS R&A Studio Tributario took part in the public consultation launched on September 20th, by the Italian Revenue Agency and concerning the draft circular letter regarding the new transfer pricing documentation requirements and penalty protection, after the Provision adopted on November 23rd, 2020.
Our professionals contributed to the consultation, focusing their observations in particular on five specific topics:
- content of the Local file related to permanent establishments
- identification of residual transactions and penalty protection
- terms and constrains for the communication of possession of adequate documentation and possible integrations and/or amendments
- content of the adequate documentation for small and medium-sized enterprises
- miscellaneous topics referred to the content of the Masterfile and of the Local file.
The full text of the contribution sent by us has been published, together with that of the other participants, on the Italian Revenue Agency’s website.