Advance Price Agreement Italia

“The information provided by Confcommercio Imprese per l`Italia on the application of price advance agreements in our country has highlighted a different situation that deserves to be brought to the attention of staff and public opinion. In the name of distribution pluralism, Federcomated supports the need for all companies operating in the country to act on the basis of the same rules, conditions and possibilities. Mario Verduci, General Secretary Federcomated Non-resident enterprises may request an advance tax agreement if conduct or will conduct their business in Italy through an establishment establishment. As part of the international ruling, advance-price agreements (APa) were introduced into Italian legislation towards the end of 2010, with budgetary instruments widely used in OECD countries, both bilateral and multilateral. These are agreements between the subject and the tax administration, which are also signed and shared by the competent authorities of the foreign jurisdictions concerned, which ensure greater security for taxpayers with regard to transfer prices and completely eliminate the risk of double taxation. As of December 31, 2012, 19 bilateral and multilateral APA applications were submitted prior to filing an application for an advance tax decision, Subjects may request a pre-presentation meeting or other procedural information by e-mailing dc.acc.accordi@agenziaentrate.it An Advance Pricing Agreement (APA) a procedural agreement between one or more subjects and one or more tax authorities, which aims to avoid transfer pricing disputes by pre-defining a set of criteria for certain cross-border controlled transactions within a specified time frame to ensure compliance with the arm length principle. With regard to recent media reports, the tax administration states that the “tax rulings” on which the articles appear to relate are agreements contrary to international standards codified at OECD and EU level, which have not been concluded in a stimulating or never concluded manner by the Italian tax administration. An early tax ruling may be requested by resident companies operating internationally and meeting one of the following requirements: tax rulings for companies with international activity “First, prior knowledge of the size of the tax for a long period of time – a fact which, as stated in Confcommercio`s response – allows Italian multinational companies to have real tax planning over five years.

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