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Italian Revenue Agency Clarifies VAT Treatment of Transfer Pricing Adjustments for Provisionally Priced Goods

|Approved Changes|Italy
Italy

The Italian Revenue Agency has published Ruling No. 214 of 19 August 2025, which clarifies the VAT treatment of transfer pricing adjustments. In particular, it addresses the VAT treatment of transfer pricing adjustments between ALFA, an Italian distributor, and DELTA, a non-resident supplier within the BETA Group. Under their local distribution agreement, ALFA purchases goods from DELTA at provisional prices, which are later adjusted quarterly to align with the arm's length principle using t…

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