The director of the Italian Revenue Office (Agenzia delle Entrate) issued regulation no. 42295/2016 (the regulation) on March 21 2016 which contains provisions for the application of the rules on advance pricing agreements (APAs) for enterprises with international activities.
The regulation clarifies the operative aspects of the procedure which leads to the conclusion of APAs with the Italian tax authorities. The procedure allows both MNEs and the Italian tax authorities to conclude APAs in different areas such as transfer pricing, flows of dividends, interests and royalties, and exit or entry values in the case of transfer of residence. The regulation applies also to proceedings that have already started although not yet concluded at the time of its enactment.
