Both Italy and France finalized their transfer pricing documentation regulations by issuing administrative instructions on, respectively, December 15, and December 23, 2010. The two countries’ regulations differ quite significantly despite the fact that both are explicitly inspired by the European Union Code of Conduct on transfer pricing documentation. This article provides a comparative review of some of the key features of each set of regulations.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...