Taxpayers who wish to obtain a prior agreement with the tax authority must submit an application for an international tax ruling. This request allows multinationals to reach an agreement with the Agency on specific cross-border tax issues (including pre-sale agreements). Antonio Zegovin is senior manager of the TP and OME team in the UK. He has extensive experience in the field of international taxation and has worked on transaction, structuring and controversy projects. He also has extensive experience in pre-agreement agreements, key procedures and transaction negotiations. Its clients include leading Italian and British multinationals. An advance pricing agreement (APA) is a procedural agreement between one or more taxable persons and one or more tax authorities, which aims to avoid transfer pricing disputes by defining in advance a number of criteria applicable to certain cross-border transactions controlled within a specified period of time, in order to ensure that they comply with the at-its-view principle. An international transfer pricing decision is essentially a unilateral advance pricing agreement. However, in their second bulletin on the international pre-decision procedure (29 March 2013), the tax authorities indicated that they had been negotiating bilateral or multilateral pre-sale agreements since the end of 2010. Nevertheless, compliance and cooperation are the key to reducing the risk of being involved in a dispute with the Italian tax administration. It is part of the multinational`s entrepreneurial strategy to disclose in advance a business model using the APA program in order to avoid the most common challenges posed by the Italian tax administration in recent years, such as TP adjustments, hidden PPPs, non-deductible administrative costs, etc.
Non-residents may apply for a tax return if they carry out their activities in Italy through an undertaking 1995, 1995, 1995, 1995 An application for prior agreement may be submitted by undertakings established in Italy and subject to the transfer pricing rules laid down in Article 110(7) of the Income Tax Code, and by Italian permanent establishments. The request concerns the determination of the subcontracting price for intercompany transactions. However, the potential scope of an early pricing agreement is flexible – it may address all of the company`s transfer pricing issues or be limited to certain issues. Before submitting an application for a tax advance agreement, taxpayers may request a prior declaration or additional information on the procedure: by sending an email to email@example.com Council Directive (EU) 2015/2376 of 8 December 2015 amending Directive 2011/16/EU as regards the mandatory automatic exchange of information in the field of taxation, which entered into force by Decree-Law 32/2007. . .