A considerable increase of transfer pricing disputes could be observed in Italy over the last decade.
Notwithstanding the rising trend of proceedings activated by the Tax Authorities and further…
If the UK leaves the EU, this would have immediate consequences for direct taxation.[1] We saw in the first post that the EU fundamental freedoms, EU provisions on State aid and EU directives and…
On 24 August 2016, the US Treasury Department issued a White Paper on “The European Commission’s Recent State Aid Investigations of Transfer Pricing Rules” (the “White Paper”), denouncing the…
Harmonisation of the efforts to discourage tax avoidance in the EU
Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…
On June 24 the British people voted in favour of the UK leaving the EU. The vote itself does not automatically imply the withdrawal from the EU: indeed, such withdrawal shall take place pursuant to…
Corporate Social Responsibility (“CSR”) has become one of the top priorities on the Agenda of almost all supranational bodies (OECD, EU, UN) and many jurisdictions. Due to the overall lack of…
“Improper and plainly undermines legal certainty and the rule of law.” This is how four U.S. senators – including the Chairman and Ranking Member of the U.S. Senate Finance Committee – recently…
The EU Commission and EU Parliament want to settle for nothing less than public country-by-country-reporting, in direct conflict with G20 BEPS adoption resolution. For many good reasons, business in…
When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation. Future generations are unlikely to view it…