Italy Issues Procedures for Corresponding Downward Adjustments

The Italian Revenue Agency has issued Measure No. 108954/2018 on the conditions and procedures for a taxpayer to request a corresponding downward adjustment following a definitive upward transfer pricing adjustment made in another jurisdiction with which Italy has a double taxation agreement (DTA) in force that allows for adequate exchange of information. The procedure is available for Italian residents and permanent establishments in Italy of non-residents.
Taxpayers that wish to apply th…