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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 Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the international tax implications of employees’ increasing global mobility, focusing on permanent establishment and transfer pricing issues, with insights from Italy
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine a recent Italian Supreme Court decision addressing evidentiary responsibilities and the selection of transfer pricing methodologies
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications
