For entities that close their fiscal year on December 31 of each year: by November 30, 2022 (extendable to February 28, 2023 under certain conditions), the appropriate transfer pricing documentation can be prepared and sent to the Internal Revenue Service for the fiscal year 2021, consisting of a Masterfile (which collects information related to the group) and a Country File (which contains information related to the resident enterprise). This is to avoid the application of the administrative penalty in the amount of 90 to 180 percent of the higher tax due in case of tax recovery related to intra-group transactions. In fact, this penalty should not be applied if, in the course of access, inspection, verification or other investigative activity, the taxpayer delivers to the tax authorities the documentation indicated by the Agency.
De Martini, Dugo, Nisli Commercialisti Associati is able to assist clients in preparing, validating and sending transfer pricing documentation.
