Transfer Pricing 2025

ITALY Law and Practice Contributed by: Marco Valdonio and Gabriella Cappelleri, Maisto e Associati

16.2 Use of “Secret Comparables” Use of “secret comparables” is not explicitly prohibited by Italian law. However, as stated, the OECD Guidelines are consistently applied by the IRA. Therefore, it may be reasonably held that the use of “secret comparables” would be permitted only if the IRA were to disclose such data to the taxpayer so as to allow the exercise of a proper right of defence.

221 CHAMBERS.COM

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