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Transfer Pricing - The Italian Experience (Paperback, Softcover reprint of the original 1st ed. 1980)
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Transfer Pricing - The Italian Experience (Paperback, Softcover reprint of the original 1st ed. 1980)
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As a part of the provisions governing the subject of the
measurement of the income of business enterprises, the fifth
paragraph, sub paragraph b), of article 53 of the Presidential
Decree no. 597 of 29 September, 1973, provides, as it is well
known, that "the difference between the normal value of goods and
services, and the consideration for transfers made and for services
rendered to companies, whose legal seat or administrative
headquarters and whose main object are not in the Italian
territory, and which either directly or indirectly control the
enterprise, or are controlled by the same company that controls the
enterprise," is tobe included in the proceeds. The second paragraph
of the successive article 56 further states that the cost of
acquisition of the goods transferred and of the services rendered
by the same enterprises is to be curtailed of any surplus tn
respect of the normal value. The same provision also applies to the
goods transferred and the services rendered by companies not having
in Italy their legal seat or their administrative office or the
main object of their activity, for account of which the enterprise
carries out an activity for the sale and placement of raw materials
or goods, or for the manufacturing or processing of products."
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