In particular, the Revenue Office identified the Masterfile and the Country-specific documentation as the documents which allow the transfer pricing documentation to be considered as acceptable and illustrated in detail the structure which the taxpayers need to comply with when preparing them, in order to benefit from the penalty protection regime. An important news contained in the provision concerns the documentation relevant to low value added services.
Paolo Besio, partner in charge of International Tax and Transfer Pricing at Bernoni Grant Thornton, commented the intervention of the Italian authority: “The Italian Revenue Office, as required by Ministerial Decree dated 14 May 2018, updated the provisions concerning the transfer pricing documentation, with effect from the current tax period.
These new provision, once again, reflects the Revenue Office intention to align with the most recents guidelines by the OECD, as well as with the EU regulations. There are various new features to be analysed, concerning both the contents and the procedure, which we will discuss together soon”.