After the legislative decree n. 49/2020, dated last June, on 17 December 2020 the Revenue Agency published the (awaited) functioning rules concerning the EU tax dispute resolution mechanism.
In this respect, the said rules recall that the controversies covered by this procedure (consisting of a first stage of interaction between tax administrations, followed by a possible arbitration phase in the event of no mutual agreement) comprise the interpretation and application of the Conventions to avoid double taxation on income and capital entered into by the Member States of the European Union. In other words, this is an effective instrument alternative to the mechanisms already provided for by the same aforementioned conventions as well as by Convention 90/436 / EEC on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (i.e. the latter substantially relating to intragroup transfer pricing and to the attribution of profits to permanent establishments).
Source PwC
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