The Italian Revenue Agency has published Ruling No. 884 of 30 December 2021, which clarifies the VAT treatment of transfer pricing adjustments applying the comparable uncontrolled price (CUP) method and later confirmed according to the application of the transactional net margin method (TNMM). The ruling confirms that such adjustments are outside the scope of VAT given that the charge (cost increase) is not directly connected to the operations (sales of goods) already carried out
Source: Orbitax
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