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Transfer Pricing in Italy

Transfer Pricing in Italy: Legal Framework, Compliance Requirements and Enforcement Mechanisms

Transfer pricing in Italy operates under a comprehensive regulatory framework that aligns closely with OECD Guidelines while maintaining specific domestic characteristics. The Italian transfer pricing regime has evolved significantly since its inception, particularly following the implementation of BEPS initiatives and updated documentation requirements that came into effect in recent years.

Legal Foundation and Regulatory Structure

The Italian transfer pricing legislation centers on Article 110, paragraph 7 of the Italian Tax Code (Testo Unico Imposte e Redditi – TUIR), enacted by Presidential Decree No. 917 of 1986 1. This foundational provision incorporates the arm’s length principle as established in Article 9 of the OECD Model Tax Convention, requiring that income components arising from transactions with related non-resident companies be determined based on conditions and prices that would have been agreed between independent parties 2.

The Ministerial Decree of 14 May 2018 provides detailed implementation guidelines for Article 110, paragraph 7, explicitly referencing international best practices and the OECD Transfer Pricing Guidelines 3. The decree establishes comprehensive guidance while maintaining flexibility for taxpayers to demonstrate compliance through various methodological approaches.

Transfer pricing rules in Italy apply to all cross-border operations involving Italian resident entities, including Italian permanent establishments of foreign companies and permanent establishments of Italian resident entities that have opted for the branch exemption regime 4.

Definition of Related Parties and Control Relationships

Italian legislation defines associated enterprises as those where one enterprise participates directly or indirectly in the management, control, or capital of another, or where the same person participates in both enterprises 5. The Ministerial Decree of 14 May 2018 specifies that participation in management, control, or capital means either a participation of more than 50 percent in the capital, voting rights, or profits of another enterprise, or the dominant influence over management based on equity or contractual constraints 6.

This definition encompasses various forms of control relationships, ensuring comprehensive coverage of potential profit-shifting arrangements between related entities. The broad scope reflects Italy’s commitment to preventing base erosion through artificial transfer pricing arrangements while maintaining clarity for legitimate business transactions.

Transfer Pricing Methods and Hierarchical Application

Italy recognizes all five OECD-approved transfer pricing methods: comparable uncontrolled price (CUP), resale price method, cost plus method, transactional net margin method (TNMM), and profit split method 7. The Italian approach follows the “most appropriate method” criterion rather than a strict hierarchical application, allowing taxpayers flexibility in selecting the method that provides the most reliable measure of arm’s length results.

Article 4 of the Ministerial Decree establishes that the most appropriate method should be selected based on several criteria: the respective strengths and weaknesses of each method, the appropriateness considering economically relevant characteristics of the controlled transaction, availability of reliable information particularly on uncontrolled comparables, and the degree of comparability between controlled and uncontrolled transactions 8.

The legislation establishes a practical hierarchy favoring traditional transaction methods over profit-based methods when they can be applied with equal reliability. The CUP method receives preference when it can be applied as reliably as other methods, reflecting the principle that direct price comparisons provide the most accurate arm’s length results 9.

Alternative methods may be used only when taxpayers can demonstrate that none of the five OECD methods could reliably determine arm’s length pricing and that the alternative method produces results consistent with what independent enterprises would achieve in comparable transactions 10.

Documentation Requirements and Penalty Protection Regime

Transfer pricing documentation in Italy operates under an optional regime that provides significant benefits for compliant taxpayers. The system, introduced in 2010 and substantially updated in 2020, offers penalty protection for companies that prepare proper documentation according to specified requirements 11.

The Italian Revenue Agency’s Provision No. 360494 of November 23, 2020, established detailed requirements for transfer pricing documentation, substantially aligning with OECD standards while maintaining specific Italian characteristics 12. The documentation structure consists of two primary components: the Master File and the Local File (Country File).

The Master File provides a comprehensive overview of the multinational group, including organizational structure, business activities, intangibles, intercompany financial activities, and financial and tax position 13. This document may be prepared in English, facilitating compliance for multinational groups with standardized documentation processes.

The Local File contains detailed information about the Italian entity and its controlled transactions, including controlled transactions, financial information, and relevant agreements 14. Unlike the Master File, the Local File must be prepared in Italian, as clarified by Italian Revenue Agency Ruling No. 174/2024, which emphasized that Italian language requirements ensure immediate understanding by tax authorities of technical aspects related to the Italian entity’s business 15.

Both documents must be prepared annually and signed electronically by the legal representative with a timestamp applied by the date of filing the relevant income tax return 16. Companies must indicate possession of transfer pricing documentation in their tax returns, and the documentation must be submitted to tax authorities within 20 days upon request.

The penalty protection regime provides substantial benefits for compliant taxpayers. Companies that prepare proper documentation and meet formal requirements receive protection from penalties that otherwise range from 90% to 180% of additional taxes assessed 17. Starting from September 1, 2024, penalties for transfer pricing adjustments without proper documentation amount to 70% of additional taxes assessed 18.

Italian legislation provides a 90-day extension possibility for completing transfer pricing documentation. Companies unable to complete documentation by the tax return deadline may file their return without indicating possession of documentation, complete the documentation within 90 days, and subsequently file an amended return 19.

Simplified Approaches and Safe Harbors

Italy has implemented simplified approaches for specific transaction types, particularly low value-adding intra-group services. Article 7 of the Ministerial Decree of 14 May 2018 regulates the simplified approach consistent with BEPS Actions 8-10 recommendations, without establishing specific thresholds 20.

Small and medium enterprises receive additional simplifications under the documentation regime. Companies with total turnover not exceeding EUR 50 million qualify as SMEs and may avoid updating comparability analysis results for two fiscal periods following the initial documentation period, provided the analysis is based on publicly available information and comparability factors remain substantially unchanged 21.

Italy does not maintain formal safe harbor provisions for transfer pricing transactions, requiring taxpayers to demonstrate arm’s length compliance through appropriate documentation and analysis for all controlled transactions 22.

Advance Pricing Agreements and Proactive Compliance

Italy’s Advance Pricing Agreement (APA) program, established in 2003 and significantly reformed in 2015, provides multinational enterprises with tax certainty through prospective agreements on transfer pricing methodologies 23. Article 31-ter of Presidential Decree No. 600/1973 governs the APA framework, with detailed procedures established by Revenue Agency Decision No. 42295/2016.

The APA scope encompasses various subjects: definition of transfer pricing methods and criteria for related party transactions, determination of entry or exit values for assets when entities transfer residence, verification of permanent establishment conditions for new business activities, definition of tax law provisions applicable to cross-border items, and attribution of profits to permanent establishments 24.

The program supports unilateral, bilateral, and multilateral APAs with terms extending up to five years, representing substantial expansion from the original two-year unilateral-only framework 25. Recent legislative changes introduced by the 2021 Budget Law include extended agreement retroactivity provisions and admission fees based on turnover, enhancing the program’s accessibility and effectiveness 26.

Mutual Agreement Procedures and Dispute Resolution

Italy maintains comprehensive dispute resolution mechanisms aligned with international standards. The country implements mutual agreement procedures (MAPs) under bilateral tax treaties and the EU Arbitration Convention for transfer pricing and permanent establishment attribution disputes 27.

Legislative Decree No. 49/2020 transposed EU Directive 2017/1852 concerning tax dispute resolution mechanisms, establishing common minimum standards for improving dispute resolution between EU jurisdictions 28. The implementation enhances taxpayer access to effective dispute resolution mechanisms while strengthening cooperation between tax administrations.

Italy has introduced unilateral corresponding adjustment procedures under Article 31-quarter of Presidential Decree No. 600/1973, allowing Italian taxpayers to request downward adjustments when foreign tax authorities make primary transfer pricing adjustments resulting in double taxation 29. This mechanism provides relief even absent mutual agreement procedures, subject to evaluation of the foreign adjustment’s compliance with arm’s length principles and availability of adequate information exchange.

Recent Italian Supreme Court decisions have clarified the admissibility of mutual agreement procedures following taxpayer-initiated adjustments, expanding access beyond traditional tax authority assessments 30. These developments reflect evolving interpretations supporting broader taxpayer access to dispute resolution mechanisms.

Country-by-Country Reporting and Transparency Measures

Italy has implemented comprehensive Country-by-Country Reporting (CbCR) requirements for large multinational enterprises. Law No. 208 of December 28, 2015, introduced CbCR obligations, with Ministerial Decree of February 23, 2017, providing detailed implementation regulations in compliance with EU Council Directive 2016/881/EU 31.

The CbCR regime applies to Ultimate Parent Entities resident in Italy of multinational groups with total consolidated revenue of at least EUR 750 million 32. Subsidiary filing obligations apply when the Ultimate Parent Entity resides in jurisdictions without CbCR requirements or adequate information exchange agreements with Italy.

Italy has recently adopted Public Country-by-Country Reporting requirements through Legislative Decree implementing EU Directive 2021/2101 33. The obligations apply to financial statements for years beginning on or after June 22, 2024, requiring large multinational entities to publicly disclose income tax information for EU member state jurisdictions.

Penalties for CbCR non-compliance range from EUR 10,000 to EUR 50,000 for failure to submit reports or submission of incomplete or untruthful data 34. The Public CbCR regime introduces additional penalties for directors of reporting entities failing to comply with disclosure obligations, with sanctions ranging from EUR 10,000 to EUR 50,000 that may be halved or doubled under certain circumstances 35.

Enforcement Approach and Audit Practices

The Italian Revenue Agency adopts a risk-based approach to transfer pricing audits, focusing particularly on large business taxpayers through specific analytical frameworks 36. The tax authority demonstrates formal and aggressive approaches to economic analyses, carefully reviewing search criteria and comparable selection processes.

Pan-European benchmark analyses may be accepted, but authorities require inclusion of Italian comparable entities to ensure relevance to local market conditions 37. This requirement reflects the authority’s emphasis on appropriate comparability adjustments and reliable benchmarking studies.

The Italian approach to transfer pricing extends beyond traditional income adjustment mechanisms. Recent Supreme Court rulings have confirmed that transfer pricing regulations apply comprehensively to interest-free intragroup loans, demonstrating the authority’s commitment to enforcing arm’s length principles across all controlled transactions 38.

Integration with International Standards and BEPS Implementation

Italy demonstrates strong commitment to international transfer pricing standards through comprehensive implementation of BEPS recommendations. The country actively participates in OECD initiatives and maintains alignment with evolving international best practices while preserving domestic legal framework coherence 39.

The Italian approach reflects broader global trends toward enhanced transparency and cooperation in international taxation. Research indicates that transfer pricing regulations, while potentially creating compliance costs, serve essential functions in protecting domestic tax bases and maintaining fair competition between multinational and domestic enterprises 40.

Italy’s regulatory framework continues evolving to address emerging challenges in international taxation, including digital economy considerations and enhanced transparency requirements. The country’s participation in multilateral initiatives demonstrates commitment to coordinated approaches while maintaining effective domestic enforcement capabilities.

The implementation of sophisticated dispute resolution mechanisms and proactive compliance tools positions Italy among jurisdictions providing comprehensive frameworks for managing transfer pricing compliance and dispute resolution. These developments support both tax administration objectives and taxpayer certainty in an increasingly complex international tax environment.

Recent Developments – Accelerated Tax Return Filing Schedule

Italy implemented substantial changes to corporate tax return filing deadlines through Legislative Decree 1/2024, issued on January 12, 2024 41. The legislation replaced the previous November 30 deadline with September 30 for taxpayers with calendar year-ends, representing a two-month acceleration that directly impacts transfer pricing documentation preparation timelines 42.

The modified deadline structure applies equally to taxpayers with non-calendar fiscal years, requiring corporate tax return submission by the last day of the ninth month following year-end rather than the previous eleventh month standard 43. This change necessitates earlier commencement of transfer pricing documentation activities to maintain eligibility for penalty protection benefits.

Extended Documentation Preparation Window

Recognizing the compressed timeline challenges, Italian legislation provides a 90-day extension mechanism for transfer pricing documentation preparation 44. Companies unable to complete documentation by the standard tax return deadline may file their return without indicating documentation availability, complete the required materials within 90 days, and subsequently submit an amended return indicating compliance 45.

This extension proves particularly valuable for Italian subsidiaries of foreign multinational groups requiring centralized documentation from parent companies with different preparation deadlines 46.

Language Requirements Clarification

The Italian Revenue Agency issued Ruling No. 174/2024 on August 21, 2024, definitively clarifying documentation language requirements 47. While Master Files may be prepared in English to facilitate multinational group standardization, Local Files (Country Files) must be prepared exclusively in Italian 48.

The ruling emphasizes that Italian language requirements ensure immediate comprehension by tax authorities of technical aspects related to Italian entity operations and intercompany transaction analysis 49.

Penalty Regime Modernization

Italy implemented comprehensive penalty reform effective September 1, 2024, reducing transfer pricing penalties while maintaining significant deterrent effects 50. The revised framework establishes penalties of 70% of additional taxes assessed for transfer pricing adjustments involving taxpayers without proper documentation, representing a substantial reduction from the previous range of 90% to 180% 51.

This penalty reduction aligns with broader Italian tax administration efforts to enhance fairness and proportionality while maintaining effective enforcement mechanisms 52. Companies maintaining compliant transfer pricing documentation continue receiving complete penalty protection for transfer pricing adjustments.

Accounting Standard Implementation: OIC 34

Revenue Recognition Framework

The Italian Accounting Body (Organismo Italiano di Contabilità) implemented OIC 34, a comprehensive accounting standard governing revenue recognition that significantly affects transfer pricing adjustment treatment 53. Effective for financial statements relating to fiscal years beginning January 1, 2024, OIC 34 establishes specific criteria for recognizing revenue from goods sales and service provisions, particularly affecting related party transactions 54.

The standard requires that related party transactions faithfully reflect the arm’s length principle and establishes that such transactions must represent conditions agreed among independent entities under market circumstances 55.

Transfer Pricing Adjustment Classification

OIC 34 fundamentally alters the accounting treatment of year-end transfer pricing adjustments, requiring classification as “variable consideration” rather than miscellaneous income or expenses 56. Adjustments related to revenues or costs must be classified directly under revenue (item A1) or costs (items B6 or B7), promoting greater consistency and clarity in financial statements 57.

This reclassification affects profitability indicators such as return on sales (ROS) by modifying the denominator relating to revenues or cost values while maintaining unchanged operating results 58.

Public Country-by-Country Reporting Implementation

Italy officially implemented Public Country-by-Country Reporting (PCbCR) requirements through Legislative Decree No. 128, published September 12, 2024, transposing EU Directive 2021/2101 59. The legislation applies to financial statements for years beginning on or after June 22, 2024, requiring large multinational entities to publicly disclose income tax information for EU member state jurisdictions 60.

Reporting Scope and Requirements

The PCbCR obligations encompass Italian parent entities of groups with consolidated revenue exceeding EUR 750 million for each of the last two consecutive financial years, Italian companies exceeding the revenue threshold on standalone bases, and Italian companies belonging to consolidated groups not established in Member States meeting the threshold 61.

Reports must be filed with the Company Registrar within 12 months of fiscal year-end and published on company websites, remaining available for public consultation for five years 62. Non-compliance penalties range from EUR 10,000 to EUR 50,000, with potential doubling under certain circumstances 63.

Supreme Court Jurisprudential Developments

Interest-Free Loan Treatment

The Italian Supreme Court issued Judgment No. 3223 on February 10, 2025, establishing comprehensive precedent regarding transfer pricing regulation application to interest-free intragroup loans 64. The Court ruled that even interest-free loans between related companies cannot escape arm’s length principle application under transfer pricing rules, reaffirming principles established in similar cases 65.

The decision clarifies that transfer pricing regulations apply when agreed consideration differs from arm’s length standards and when no consideration exists despite arm’s length expectation of compensation 66. This ruling significantly impacts multinational groups utilizing interest-free financing arrangements between related entities.

OECD Principle Reinforcement

Supreme Court decisions Nos. 10577/2024 and 10499/2024 reinforced fundamental OECD transfer pricing principles, particularly regarding burden of proof allocation and methodological requirements 67. The Court emphasized that tax authorities must conduct clear and precise analysis of functions, risks, and assets when applying transfer pricing methods, particularly the cost-plus method 68.

The decisions consolidated the principle that taxpayers bear the burden of proving transactions were conducted at arm’s length under the “proof-proximity principle,” while tax authorities must demonstrate existence of transactions between related parties at apparently non-arm’s length prices 69.

Domestic Transaction Scope Clarification

Supreme Court Judgment No. 5859 of 2024 definitively clarified that transfer pricing legislation does not apply to transactions between affiliated companies both resident in Italy 70. This ruling reinforces positions established in Legislative Decree No. 147/2015, confirming that transfer pricing regulations apply exclusively to cross-border operations involving Italian resident entities 71.

VAT Treatment Clarifications

The Italian Revenue Agency issued Answer No. 266/2024 on December 18, 2024, providing guidance on transfer pricing adjustment relevance for VAT purposes in determining taxable bases for intercompany transactions 72. The guidance specifically addresses scenarios involving intra-community purchases, imports, processing, and exports within multinational group structures 73.

Practical Implications and Implementation Considerations

These comprehensive changes require multinational enterprises to reassess transfer pricing compliance strategies, documentation preparation timelines, and accounting treatment methodologies. The accelerated filing deadlines necessitate earlier commencement of transfer pricing documentation activities, while the 90-day extension provides flexibility for complex multinational group coordination 74.

The Supreme Court’s emphasis on interest-free loan treatment requires careful evaluation of all intragroup financing arrangements, with particular attention to commercial justification documentation 75. Companies must ensure robust documentation supporting any deviations from market-standard financing terms while maintaining consistency with broader transfer pricing policies.

The implementation of OIC 34 accounting standards fundamentally alters financial statement presentation of transfer pricing adjustments, requiring coordination between tax and accounting teams to ensure proper classification and maintain audit trail integrity 76. The public country-by-country reporting requirements introduce additional transparency obligations that extend beyond traditional tax compliance into public disclosure responsibilities.

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  67. CMS Law Now, Italian Supreme Court Upholds OECD Transfer Pricing Rules, June 21, 2024, https://cms-lawnow.com/en/ealerts/2024/06/italian-supreme-court-upholds-oecd-transfer-pricing-rules
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  70. International Tax Review, Transfer pricing legislation not applicable to domestic intercompany transactions, March 19, 2025, https://www.itrworldtax.com/NewsAndAnalysis/Transfer-pricing-legislation-not-applicable-to-domestic-intercompany-transactions/Index/1961
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  72. Bloomberg Tax, Italy Tax Agency Clarifies Transfer Pricing Adjustments for Intercompany VAT Transactions, January 2, 2025, https://news.bloombergtax.com/daily-tax-report-international/italy-tax-agency-clarifies-transfer-pricing-adjustments-for-intercompany-vat-transactions
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  74. International Tax Review, Italy: Year-end transfer pricing adjustments under new accounting standard, May 14, 2025, https://www.internationaltaxreview.com/article/2esilt42n0evtlsxzw3cw/sponsored/italy-year-end-transfer-pricing-adjustments-under-new-accounting-standard
  75. Chambers Practice Guides, Transfer Pricing 2025 – Italy, April 10, 2025, https://practiceguides.chambers.com/practice-guides/transfer-pricing-2025/italy
  76. TPC Group, Italy: Transfer Pricing Adjustments and their impact, May 28, 2025, https://en.tpcgroup-int.com/news/italy-transfer-pricing-adjustments-and-their-accounting-and-tax-impact/
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