WITH TP audits becoming more aggressive, and resulting in litigation,
the Italian Revenue has increasingly been relying more on MAPs.
To
infuse consistency in the working of the officers and to provide guidance, the
Italian Revenue Agency has early this month come out with a Circular, which
provides clarifications on several contentious issues in the context of MAP and
other remedies.
The
Circular makes reference to the availability of two different types of MAPs -
one in the context of DTAA and other with reference to the EU Arbitration
Convention.
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