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• Italy - Deadline for Italian Transfer Pricing communication form expires on 28 DECEMBER 2010

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  Carsten Schmid    Premium Member

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  Italy - Deadline for Italian Transfer Pricing communication form expires on 28 DECEMBER 2010

  Relief from administrative penalties in case of tax assessments – Deadline for communication to Italian Tax Authorities
  
  In September this year, the Italian Tax Authorities introduced new transfer pricing documentation requirements for Italian resident companies. In the case of tax assessments, relief from penalties will be granted to those companies which, during the course of an audit, are able to provide the tax authorities with a Masterfile and a National Documentation report (i.e., a country file).
  
  For previous fiscal years still open to audit, the possession of the transfer pricing documentation will be communicated by filing a standard electronic communication by 28 December 2010, at the latest.
  What does this standard electronic communication mean?
  
  - Any multinational, which has its transfer pricing documentation (almost) ready covering all years for the 2006 – 2009 period, is strongly recommended to file the “standard electronic communication” to avoid the 100% / 200% administrative penalty in the case of a future profit adjustment;
  - Any multinational which does not file the “standard electronic communication” may have a higher risk of being selected for a transfer pricing audit.
  What topics are not covered by filing electronic communication?
  - The communication does not protect against criminal charges;
  - Filing the communication is optional; and
  - Even after the communication is filed, the tax authorities can still ask for transfer pricing documentation starting from 1 January 2011. The taxpayer is obliged to comply with the ten-day deadline to provide said documentation
  
  For the current fiscal year 2010, the communication will be filed at the time the company files its annual tax return. The deadline to file the 2010 tax return is 30 September 2011 for companies with a 31 December year-end.
  Further guidance is provided in the publication dated15 December 2010, where the following practical topics were addressed:
  
  - Transfer Pricing Documentation (TPD) must be updated yearly. However, Small and Medium Sized Companies may update their TPD every two years, unless "significant changes" occurred during that period.
  - Italian companies with non-resident parent companies may prepare their TPD (Master file and Local files) in English.
  - TPDs which do not comply with the OECD Transfer Pricing Guidelines in terms of providing a functional and economic analysis will not qualify for relief from administrative sanctions granted by the Italian Legislators.
  
  • 16 Dec 2010, 2:56 pm
  Carsten Schmid wrote: > Relief from administrative penalties in case of tax assessments – > Deadline for communication to Italian Tax Authorities > > In September this year, the Italian Tax Authorities introduced new > transfer pricing documentation requirements for Italian resident > companies. In the case of tax assessments, relief from penalties will > be granted to those companies which, during the course of an audit, > are able to provide the tax authorities with a Masterfile and a > National Documentation report (i.e., a country file). > > For previous fiscal years still open to audit, the possession of the > transfer pricing documentation will be communicated by filing a > standard electronic communication by 28 December 2010, at the latest. > What does this standard electronic communication mean? > > - Any multinational, which has its transfer pricing documentation > (almost) ready covering all years for the 2006 – 2009 period, is > strongly recommended to file the “standard electronic communication” > to avoid the 100% / 200% administrative penalty in the case of a > future profit adjustment; > - Any multinational which does not file the “standard electronic > communication” may have a higher risk of being selected for a > transfer pricing audit. > What topics are not covered by filing electronic communication? > - The communication does not protect against criminal charges; > - Filing the communication is optional; and > - Even after the communication is filed, the tax authorities can > still ask for transfer pricing documentation starting from 1 January > 2011. The taxpayer is obliged to comply with the ten-day deadline > to provide said documentation > > For the current fiscal year 2010, the communication will be filed at > the time the company files its annual tax return. The deadline to > file the 2010 tax return is 30 September 2011 for companies with a 31 > December year-end. > Further guidance is provided in the publication dated15 December > 2010, where the following practical topics were addressed: > > - Transfer Pricing Documentation (TPD) must be updated yearly. > However, Small and Medium Sized Companies may update their TPD every > two years, unless "significant changes" occurred during that period. > - Italian companies with non-resident parent companies may prepare > their TPD (Master file and Local files) in English. > - TPDs which do not comply with the OECD Transfer Pricing Guidelines > in terms of providing a functional and economic analysis will not > qualify for relief from administrative sanctions granted by the > Italian Legislators.
• 
  Jos Chrispijn    Group moderator

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  Re: Italy - Deadline for Italian Transfer Pricing communication form expires on 28 DECEMBER 2010

  For the complete press release, please refer to http://www.tpa-global.com/press
  
  • 18 Dec 2010, 10:01 pm
  Jos Chrispijn wrote: > For the complete press release, please refer to > www.tpa-global.com/press
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