Italy: Comparable entities must be included in transfer pricing comparability analysis (Supreme Court decision)
A Supreme Court decision concerning whether potentially comparable entities can be excluded from a transfer pricing comparability analysis solely based on their lower profit levels or losses.
The Supreme Court on July 26, 2024, held that potentially comparable entities cannot be excluded from a transfer pricing comparability analysis solely based on their lower profit levels or losses in certain years.
Read a September 2024 report prepared by KPMG’s EU Tax Centre