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Documentation Structure per the 2020 Decree

January 1, 2025
Documentation Structure per the 2020 Decree

Documentation Structure per the 2020 Decree

Penalty protection for transfer pricing adjustments requires that documentation exactly follows the structure outlined in the 2020 Ministerial Decree, mirroring the OECD/BEPS framework. The Master File may be in English, but the Local File is required in Italian. Both must be digitally signed and provided upon request.

Source:

Italian Guidance (Implementation Decree, Circular 15/2021)

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