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Franco Pozzi and Simona Zangrandi of Biscozzi Nobili & Partners examine secondary transfer-pricing adjustments under Italian tax practice

06 March 2026 by Studio Legale e Tributario Biscozzi Nobili & Partners - Italy

With judgment No. 4699 of November 26, 2025, the First Instance Tax Court of Milan ruled that, under the combined provisions of the Italy-Switzerland Double Taxation Treaty and OECD Commentary (paragraph 12.25), payments exceeding the arm's length value are not taxable as “royalty” in Italy.