TP Liabilities on Criminal Tax in Italy: Assessing, Adopting and Avoiding


During the course of tax audits, Italian tax authorities often challenge the value of the goods or services subject to intra-group relationships.
These disputes are particularly relevant for the Italian entity/company that carries out such inter-company transactions.
Should there be no coincidence between the declared assessments and the assessments made - based on Article 9 Testo unico delle imposte sui redditi (TUIR) - potential liability scenarios related to the crime of unfaithful declaration could open up.

Published in: International Tax Review (ITR) - 15 April 2020