Italian Transfer Pricing documentation – New measure and recent clarifications released

Introduction

On September 20^th, 2021, the Italian Revenue Agency (the “IRA”) released for public consultation until October 12, 2021, the draft circular letter (the “Circular”) containing clarifications on the correct application of the transfer pricing documentation rules (the “TP documentation”) contained in the Administrative Provision n. 360494 of November 23^rd, 2020 (the “Provision”). The preparation of the documentation serves to benefit of the penalty protection regime in the event of a tax audit.

The following paragraph contains a summary on the main relevant clarification to the Provision as indicated in the Circular. We expect the final version of the Circular to be released not before the end of October, with no or small amendments.