Italian TP ruling clarifies burden of proof and method selection

Federico Vincenti, Carola Valente Della Rovere
15/06/2026

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine a recent Italian Supreme Court decision addressing evidentiary responsibilities and the selection of transfer pricing methodologies.

A recent decision of the Italian Supreme Court (Judgment No. 15698 of May 22 2026) provides significant guidance on two of the most debated issues in transfer pricing litigation: the allocation of the burden of proof and the selection of the most appropriate transfer pricing method.

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