The Shift in the Burden of Proof in regard to Transfer Pricing

Journal
Author
Mastellone, P.
Country
Italy
Published Date
Issue
European Taxation 2011 (Volume 51), No. 5
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this note, the author discusses the development of the transfer pricing regime in Italy in the context of recent legislative and case law developments that, inter alia, clarify that the initial burden of proof in this area is on the tax authorities.