Intangibles, zero remuneration and burden of proof. An Italian view

04/05/2023

In this article, we set out the transfer pricing complexities that can result from different forms of corporate restructuring. 
 
Corporate reorganizations often involve the centralization of intangible assets and risks, and the related potential profit – our article delves into some points to take into consideration to minimize potential risk exposure.

We will be pleased to share views on this topic with you. Please feel free to circulate to clients should you find interesting.

 

Published on International Tax Review March 17, 2023

 

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Article: https://www.internationaltaxreview.com/article/2bevp53i2xxppb3rrw074/sponsored/intangibles-dempe-and-corporate-reorganisations-what-to-watch-out-for-in-transfer-pricing