This week, Copenhagen Economics submitted comments to the Italian Ministry of Economy and Finance’s (MEF)’s public Transfer Pricing consultation.
We point out that the draft guidance does not provide taxpayers and tax administrations with a clear and specific guidance on when and whether to consider the results stemming from the application of the transfer pricing methods to be at arm’s length.
Rather, we believe that some proposed guidance could create confusion and leave the taxpayer in uncertainty.
Our concerns relate to the following issues:
- The concepts of “control” and “dominant influence” are not clear
- The wording used with regard to the financial indicator is misleading
- The meaning of “aggregation of transactions” is to be defined
- The “fair” position within the arm’s length range ought to be clarified
For further information, please contact Vincenzo Zurzolo