(France) Already in 2023, the French government stated that their new plan to combat tax- and customs (‘public finances’) fraud would introduce new measures to strengthen transfer pricing control/audits among taxpayers. These measures have now been introduced into law by the French Budget Bill 2024 and are applicable as of 1 January 2024.
(Italy) A legislative decree published on 12 January 2024 has changed the deadline for filing the corporate income tax return for fiscal years starting after 31 December 2023. This change also has an impact on transfer pricing and the so-called penalty protection regime for preparing transfer pricing documentation.
This news flash is intended to provide you with a short introduction into these new measures. These new rules may be of importance for MNEs with a presence in one of these countries and they should consider if there is an impact on the transfer pricing (compliance) strategy. In summary, the following will change:
- In France, the existing thresholds will be lowered and the importance of having qualitative transfer pricing documentation will increase.
- In Italy, the corporate income tax return deadlines will be shortened from 11 to 9 months, also impacting deadlines for preparing and signing transfer pricing documentation under the Italian penalty protection regime.