Personal liability for corporate tax penalties and new criminal law applicable to transfer pricing matters

The relevance of the different rules (domestic rules versus OECD Guidelines), the new law on personal liability for corporate tax penalties and the new criminal law are discussed. The tax penalties applicable in tax audits on transfer pricing are described, and the increasing relevance of documentation gathered by the Italian company with the help of its foreign parent to be submitted to the tax authorities in the event of a tax assessment is pointed out.