Italy Tax Agency Clarifies Transfer Pricing Adjustments for Intercompany VAT Transactions

The Italian Revenue Agency issued Dec. 18 Answer No. 266/2024, clarifying the transfer pricing adjustments for intercompany VAT transactions. The taxpayer is a company carrying out intra-community purchases in Italy and imports of goods, which are processed and exported as a final product to the U.S. by a third party, for the benefit of another company in the same company group. The taxpayer sought clarification on whether the transfer pricing adjustments can be considered relevant for VAT purposes, in determining the taxable base of the export transactions underlying the adjustments. The Agency determined that: 1) transfer pricing adjustments are relevant ...