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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the conditions that transfer pricing documentation must satisfy to allow taxpayers to benefit from Italy’s penalty protection regime concerning hybrid mismatches
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how an Italian Supreme Court ruling has clarified the transfer pricing treatment of transactions between affiliated Italian companies
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a transfer pricing-related ruling by the Italian Supreme Court that effectively clarifies the role of OECD guidelines and the ‘best method’ rule