transfer price in Italy
OBLIGATION TO COMMUNICATE TO THE TAX AUTHORITIES THE DOCUMENTATION RELATED TO THE TRANSFER PRICING
The article 26 of the Law Decree No. 78, dated May 31, 2010, containing the rules regarding the transfer pricing, introduces the obligation, in order to avoid the penalties about the incorrect tax return, to communicate by electronic means to the Italian tax Authorities the production of the documentation about the transfer pricing.
Starting from 2010, the communication will have to be submitted with the same recurrence of the submission of the annual income tax return, 30th September of each year, instead, for the previous years it will have to be submitted within the 28th December 2010 (the communication can be submitted also after December, 28 2010 as long as a tax assessment has not begun yet).
According to the above rule, the controlling or controlled companies of a multinational group and the permanent establishment of non-resident company have to submit, within 10 days from the request of the Italian Tax Authorities, the documentation defined by the tax Authorities provision dated September 29, 2010.