-
The Italian tax authorities, in Ruling No. 214 (August 2025), confirmed that transfer pricing adjustments under the TNMM may trigger VAT when directly linked to specific supplies, aligning with EU-level interpretations and CJEU guidance.
-
Supporting documentation, including affected invoices and detailed adjustment breakdowns, was crucial in establishing VAT relevance, as the adjustments were treated as direct revisions of transaction values rather than broad year-end settlements.
-
Multinational groups should proactively review contracts, document links between adjustments and supplies, align invoicing/accounting with VAT rules, and seek rulings where needed, as EU tax authorities intensify scrutiny of intercompany transfer pricing adjustments.
Source: www.internationaltaxreview.com
Latest Posts in "Italy"
- Italy Uncovers €42.8 Million VAT Fraud in Luxury Car Trade Across Europe
- EPPO Uncovers EUR 42.8 Million VAT Fraud in Italy’s Luxury Car Market
- €42.8 Million VAT Fraud Uncovered: Luxury Cars and Assets Seized in Italy Investigation
- VAT Treatment of Photovoltaic Plant Sales: Mobile vs. Immobile Asset Classification
- Tax Office Denies VAT Refunds for Solar Installations on Agricultural Farms Due to Indeductibility Issues