Borioli & Colombo Associati, Tax Advisers (Milan) contributed to two public consultations by the Italian Ministry of Finance and OECD, respectively, on the EU Commission’s Proposals for Introducing New Taxation Rules for Digital Enterprises and on Future Revision of Chapter VII (Intra-group Services) of the Transfer Pricing Guidelines.
Borioli & Colombo has recently contributed to the public consultations issued by the Italian Ministry of Finance and the OECD relative to very hot topics for international taxation of multinationals.
In the first consultation, the Ministry of Finance requested contributions commenting on the recent proposals by the EU Commission for introducing, under certain conditions, a temporary tax on digital services provided to EU final clients and then a new definition of permanent establishment, to be included also in the Member States tax treaty network. The procedure ended on 22 June, 2018.
Concerning the OECD, the consultation referred to the future revision of Chapter VII (Intra-group Services) of the Transfer Pricing Guidelines, one of the most sensitive for any MNE. The procedure ended on 20 June, 2018, and comments have been published on 29 June on the OECD website.
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