ARTICLE · 12 NOVEMBER 2021

First Application Of The New Italian Rules On Transfer Pricing Documentation

RP Legal & Tax

Explore more from RP Legal & Tax

Tax Authorities with Provision no. 360494 of 23 November 2020 introduced substantial changes to the rules related to transfer pricing documentation that allows the non-application of penalties...

ItalyTax

Tax Authorities with Provision no. 360494 of 23 November 2020 introduced substantial changes to the rules related to transfer pricing documentation that allows the non-application of penalties for fraudulent tax return in case of transfer pricing adjustments (so-called penalty protection).

These new rules are applicable for the first time on the tax year 2020 within the upcoming date to forward the relative tax return.

The Provision introduced several changes and the main ones are briefly described below:

Type of documents to be prepared: The documentation for all Italian entities is now composed by both Masterfile and Local File.
Changes to the content of the Masterfile, as:

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

New Developments Regarding Corporate Welfare Family Members And Taxation Of Fringe Benefit Cars

Toffoletto De Luca Tamajo e Soci

Cryptocurrency Taxation In Italy: Tax Rates, Tax Returns And The RW Section

Boccadutri International Law Firm

Sicily IRPEF Refund 2026: Up To 60% For New Residents

Boccadutri International Law Firm

Welcome To Spada Partners From Milan

GGI | Global Alliance

The Italian Flat Tax Regime For HNW And The UK Pension Opportunity

European UnionTax

Spectrum IFA Group

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Tax Authorities
- Transfer Pricing

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

Italy's 2026 Budget Law: Practical Takeaways For Businesses

The 2026 Italian Budget Law was published in the Italian Official Gazette on December 31, 2025. It introduces significant changes to Italy's tax framework with material implications for investors, financial intermediaries, and multinational groups.

Cryptocurrency Taxation In Italy: Tax Rates, Tax Returns And The RW Section

Italy's 2025 Budget Law significantly reformed cryptocurrency taxation, raising capital gains rates to 33% from 2026 and eliminating the previous €2,000 annual threshold. Understanding these changes is crucial for anyone holding crypto-assets in Italy, as new reporting obligations and tax rates now apply to all realized gains, staking rewards, and other crypto-related proceeds.

Boccadutri International Law Firm

Donation Of Shares In Foreign Companies: How To Calculate Capital Gains For Italian Tax Purposes

In response no. 114 issued on May 23, 2024, to a request for a ruling, the Italian tax authorities provided clarifications on the value to be assumed for tax purposes in Italy for capital gains...

ALTENBURGER LTD legal + tax

OnlyFans Taxes: Legal Guide For Creators On Income, VAT And Compliance

OnlyFans taxes explained: income tax, VAT, tax rates, and legal risks for creators. Learn how to stay compliant and optimize your OnlyFans earnings with expert legal advice.

Arnone & Sicomo

Italy Introduces 5% VAT Rate On Art Sales And Imports: A Strategic Boost For The Art Market

As of July 1, 2025, Italy has implemented a reduced 5% VAT rate on the sale and importation of artworks, antiques, and collectors' items.

Sicily IRPEF Refund 2026: Up To 60% For New Residents

Sicily offers new residents moving from abroad a substantial IRPEF refund of up to 60% for three years, provided they meet specific residence, income, and property investment requirements. This regional grant aims to attract workers and pensioners to the island, particularly to smaller municipalities with fewer than 5,000 inhabitants.

Boccadutri International Law Firm

New Tax Penalties Regime Enters Into Force

Starting as from September 1, 2024, new regulations regarding tax administrative penalties introduced by Decree No. 87 of June 14, 2024 ("Decree"), have officially come into effect.

Gianni & Origoni

Tax Authority: Instructions On Tax Benefits Provided By 2026 Budget Law

The Italian Tax Authority has issued operational instructions clarifying the application of tax relief measures introduced by the 2026 Budget Law, addressing both salary increases from contract renewals and special work allowances. These guidelines detail which income components qualify for preferential tax treatment and establish specific conditions for employees to benefit from reduced taxation rates on certain employment-related payments.

DL-Law Avvocati Giuslavoristi

Flat Tax For New Residents In Italy, Present And Future

Discover the preferential tax regime under Article 24 bis of the TUIR for new residents in Italy: requirements, latest amendments (Decree Law 113/2024) and implications for international clients and returning Italian citizens.

Boccadutri International Law Firm

The 7% Tax Regime For Pensioners In Italy

Italy's special 7% tax regime for pensioners relocating to Southern regions has been expanded to include towns with up to 30,000 residents, opening up significantly more location options with better access to essential services. Understanding the qualification requirements and strategic financial planning opportunities can help maximize the benefits of this attractive tax incentive for foreign retirees.

Spectrum IFA Group