Decree No. 50 published on 24 April 2017 was implemented on 15 June 2017. According to Article 59 of Decree Law No 50/2017, a corresponding downward adjustment leading to a lower taxable income will no longer be subject to a mutual agreement procedure (MAP), but will also be available after international audits, the results of which are shared by the cooperating countries (in accordance with rules to be defined by the Italian tax authorities) for a definitive arm’s length transfer pricing adjustment in a country with which Italy has a tax treaty enabling an appropriate exchange of information.
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