"CIRC. 64/2016-transfer pricing operations "
Close to the deadline for submitting returns Only SC income tax return to 30.06.2016 and recalling the previous circular needle. 72 of 2014 and n. 59 of 2010, we would like to remind you once again that the Transfer Pricing legislation provides for the non-application of penalties if the taxpayer documents financial administration that there is correspondence between the c.d. "transfer pricing" i.e. the fees charged for transactions with Group companies (subsidiaries, parent companies or "sisters") residing abroad and their fair value.
As already mentioned, we consider highly likely that Provincial Revenue Agency soon begins to check and verify the accuracy of documents (Master file and Country files).
In this regard it should be noted that the study will send tax returns do not tick the appropriate flag that assumes that the customer can prove that documentation. Therefore in the event that this does not correspond to reality, please let us know by November 30, 2016.
The study remains at your disposal for any clarification even with specific reference to the behavior of your company for the annuities payable by fiscally still open.
Sydney, September 23, 2016
Dr. Maurizio Dal Mas