Franco Pozzi

On 26 November 2021, Italian Revenue Agency published Circular Letter no. 15/E (the “Circular”) providing clarifications on the TP documentation rules contained in the Instruction.

In Italy, new rules came into force regarding the structure, content and submission of the transfer pricing documentation. These changes apply to both the master file and the local file and have significant implications for the taxpayer.

An overview on recent case laws in Italy.