Operational instructions on transfer pricing

Through Circular 16/E dated May 24th (henceforth “Circular”), the Italian Revenue Agency provided further operational instructions on Transfer Pricing.

The content of the Circular rests on the centrality of the concept of “comparable transaction,” returning to the correct notion of the arm’s length interval and recalling what was clarified by the Decree of the Ministry of Economy and Finance of May 14th, 2018.

In addition, the Circular focuses in particular on three main aspects related to Transfer Pricing analyses:

  1. lack of comparability in the analyses;
  2. compliance of arm’s length values;
  3. loss-making transactions.

The attached document analyzes the main changes introduced.


Andreea Hamza