Transfer Pricing and Tax Law – BEPS Actions 8, 9, 10 and the Italian System: an Assessment

The Italian experience in Transfer pricing audits and assessments dates back to the early eighties, and thus is almost four decades old. In this timespan Tax offices in the peninsula have developed a more and more precise and aggressive application of this technique, relying on the law, internal circular letters and instructions. As the international scenario developed, the Ministry of Finance in 2018 issued a landmark Regulation, codifying most of these best practices, thus creating a more transparent environment for taxpayers and investors in the country.