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Transfer Pricing

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Our transfer pricing experience is far reaching. CMS Adonnino Ascoli & Cavasola Scamoni has advised on a number of negotiations involving issues concerning the determination of intra-group prices, and more generally, for cross border transactions. Our team’s experience is quite vast and includes the assessment of the value of goods and services, assistance in the international al ruling operations, in the selection and use of alternative methods and for the definition of all the necessary documentation. 


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20/05/2022
DEBRA – The new EU tax ini­ti­at­ive aim­ing at pro­mot­ing a fair and sus­tain­able...
With­in the EU a wide­spread asym­metry ex­ists between debt and equity fin­an­cing. Usu­ally, in­terest is tax de­duct­ible from the cor­por­ate in­come tax base while di­vidends do not be­ne­fit from such ad­vant­age...
29/03/2022
Ap­plic­a­tion of State aid law to tax meas­ures: 2021 re­view and 2022 out­look
By sev­er­al rul­ings is­sued in 2021, the Court of justice of the EU (CJEU) has spe­cified its case-law on the veri­fic­a­tion of two re­quire­ments for tax meas­ures to fall with­in the scope of State aid: the...
28/03/2022
Itali­an court re­cog­nises ret­ro­act­ive ex­emp­tion on di­vidends to for­eign...
In judg­ment No. 49/2022, the first in­stance Court of Pes­cara re­cog­nised that dis­tri­bu­tion of di­vidends from a res­id­ent com­pany to a non-res­id­ent fund must be gran­ted with an ex­emp­tion re­gime from the...
28/03/2022
Itali­an court re­cog­nises ret­ro­act­ive ex­emp­tion on di­vidends to for­eign...
In judg­ment No. 49/2022, the first in­stance Court of Pes­cara re­cog­nised that dis­tri­bu­tion of di­vidends from a res­id­ent com­pany to a non-res­id­ent fund must be gran­ted with an ex­emp­tion re­gime from the...
28/03/2022
Ger­many: Cross-bor­der em­ploy­ee as­sign­ments - li­ab­il­ity for wage tax?
The de­cis­ive factor for wage tax li­ab­il­ity in the in­ter­na­tion­al as­sign­ment of em­ploy­ees is not who pays the wage. For the em­ploy­ee, the ques­tion is: in which coun­try must the in­di­vidu­al pay tax on his...
07/03/2022
The Su­preme Court con­firms re­duced with­hold­ing tax on di­vidends dis­trib­uted...
The Su­preme Court (Or­din­ances, no. 523/2022 and no. 524/2022) has once again ruled on wheth­er en­tit­ies oth­er than cor­por­ate com­pan­ies - and, in par­tic­u­lar, Span­ish in­vest­ment and pen­sion funds - are also...
07/03/2022
The En­ergy De­cree re­opens the terms for the re­valu­ation of non-lis­ted par­ti­cip­a­tions
De­cree n. 17/2022 has even­tu­ally re­in­tro­duced the spe­cial tax re­gime that al­lows the step-up of par­ti­cip­a­tions held in non-lis­ted com­pan­ies by in­di­vidu­als for cap­it­al gain tax pur­poses. This spe­cial...
07/03/2022
Coun­try tax guide
CMS Coun­try Tax Guide provides pre­lim­in­ary in­form­a­tion on the main tax fea­tures for 13 jur­is­dic­tions for high net-worth in­di­vidu­als, en­tre­pren­eur­i­al fam­il­ies, their ad­visors and fam­ily of­fices in con­nec­tion...
04/03/2022
The En­ergy De­cree re­opens the terms for the re­valu­ation of non-lis­ted par­ti­cip­a­tions
De­cree n. 17/2022 has even­tu­ally re­in­tro­duced the spe­cial tax re­gime that al­lows the step-up of par­ti­cip­a­tions held in non-lis­ted com­pan­ies by in­di­vidu­als for cap­it­al gain tax pur­poses. This spe­cial tax...
03/02/2022
Tax treaty between France and Colom­bia: Fi­nally entered in­to force!
France has an ex­tens­ive net­work of tax treat­ies in Lat­in Amer­ica. However, Colom­bia was still a coun­try with which France had no tax treaty entered in­to force, des­pite a tax treaty be­ing signed back in...
10/01/2022
CMS Next
What’s next? In a world of ever-ac­cel­er­at­ing change, stay­ing ahead of the curve and know­ing what’s next for your busi­ness or sec­tor is es­sen­tial.At CMS, we see ourselves not only as your leg­al ad­visers but also as your busi­ness part­ners. We work to­geth­er with you to not only re­solve cur­rent is­sues but to an­ti­cip­ate fu­ture chal­lenges and in­nov­ate to meet them.With our latest pub­lic­a­tion, CMS Next, our ex­perts will reg­u­larly of­fer you in­sights in­to and fresh per­spect­ives on a range of is­sues that busi­nesses have to deal with – from ESG agen­das to re­struc­tur­ing after the pan­dem­ic or fa­cing the di­git­al trans­form­a­tion. We will also share with you more about the work that we are do­ing for our cli­ents, help­ing them in­nov­ate, grow and mit­ig­ate risk.To be able to provide you with the best sup­port, we im­merse ourselves in your world to un­der­stand your leg­al needs and chal­lenges. However, it is equally im­port­ant that you know who we are and how we can work with you. So, we in­vite you to meet our ex­perts and catch a glimpse of what is hap­pen­ing in­side CMS.En­joy read­ing this pub­lic­a­tion, which we will up­date reg­u­larly with new con­tent.CMS Ex­ec­ut­ive Team
30/12/2021
Pil­lar 2: Mod­el rules to im­ple­ment in­ter­na­tion­al tax re­form pub­lished
The OECD pub­lished on 20 Decem­ber 2021 the tech­nic­al de­tails of the im­ple­ment­a­tion of "Pil­lar 2" to es­tab­lish min­im­um tax­a­tion of mul­tina­tion­al groups. The gen­er­al ar­chi­tec­ture of the rules is con­sist­ent...