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An overview by Alma LED, Taxand Italy
In an interview with Tax Notes, Diletta Fuxa and Giuseppe Ferrisi from Alma LED, Taxand Italy, have analysed a recent court decision on transfer pricing.
In the decision, The Italian Supreme Court overturned a lower court’s ruling in the case of ING Bank NV v. Agenzia Delle Entrate regarding transfer pricing of intragroup loans between an Italian subsidiary and a Dutch affiliate.
The Court found that neither party provided sufficient evidence for the correct arm’s-length interest rate, and the lower court’s ruling was inconclusive.
Read the full article here.
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