-
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 Requires €50,000 Bank Guarantee for Non-EU Businesses’ VIES VAT Registration
- In 2026, Automatic Low-Risk VAT Refunds with AI to Boost Anti-Fraud Efforts
- Commission Backs Italy’s VAT Derogation on certain vehicles Through 2028
- Briefing Document & Podcast: Italy’s E‑Invoicing, E‑Reporting, and E‑Transport: Scope, Timeline & Key Details
- Standard VAT Rate Applies to Hearing Aid Repairs; Reduced Rate Only for Sales, Not Services
