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Transfer pricing: burden of proof on tax administration

|Approved Changes|Italy
Italy

The Italian Supreme Court gave its decision on 26 June 2006, registered on 13 October 2006, in Case No. 22023. Details of the decision are summarized below.

(a) Facts. An Italian company purchased vehicles from its foreign affiliates and distributed them on the Italian market. The costs for the (i) maintenance and repair and (ii) the liability for damages from the use of the vehicles, which would in principle lie with the foreign manufacturers, stayed with the I…

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