GTC GlobalApr 21, 20182 min readPermanent EstablishmentAttribution of profit to Permanent EstablishmentsRecognizing the need to bring greater clarity, objectivity, and predictability in the matter of attribution of profit to a Permanent...
GTC GlobalJul 20, 20171 min readTax Treaty vs Domestic LawTax-less Corporate Income: Balance against White Income, Grey Rules and Black HolesThe potential of globalization and digitization is clearly shown in international taxation which is in the phase of complete overhaul....
GTC GlobalJun 15, 20172 min readTransfer PricingTransfer Pricing Audits: Suitability of Transfer Pricing DocumentationArticle 26 of Legislative Decree No. 78/2010 introduced in Italy a rewarding regime related to the non-application of penalties involving...
GTC GlobalJun 11, 20161 min readTransfer PricingTransfer Pricing: An Overview of the Italian Supreme Court’s Recent RulingsRulings on transfer pricing matters issued in the last few years by Italian Courts covered various themes. Among these, the Tax...