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Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 3/21/2013

Italy - APA statistics (March 2013) 

March 21:   The Italian tax authorities on 20 March 2013 issued the second report on what may be referred to as the Italian advance pricing agreement (APA) program.*


*The Italian “international tax ruling” program (under the Italian “international standard ruling” procedures) allows for a ruling similar to what would be described as a unilateral APA. Italy also initiated a program to allow for bilateral and multilateral APAs in 2010.

According to the data from the March 2013 report, the number of companies filing for an “international tax ruling” reflects a significant increase over the number of taxpayers having filed for a ruling over the past three years.


Read a March 2013 report [PDF 63 KB] prepared by the KPMG member firm in Italy:
Transfer Pricing - March 2013: APAs in Italy - the Italian tax authorities issued the second Italian International Standard Ruling Report

APA statistics

As of 31 December 2012—


  • 19 bilateral APAs were outstanding


  • 135 applications have been submitted since the ruling system was first enacted (with 83 applications submitted over the past three years)


  • 123 applications have been accepted, and as of 31 December 2012,
  • 56 were concluded with an agreement
  • 54 applications were still pending
  • 13 were withdrawn either by taxpayers or the tax authorities.
  • 52 requests were submitted over the first five years of the ruling program


  • 83 requests were submitted for the period 2010-2012, with 38 of these submitted in 2012 alone

Time for processing, completion

In general, the time for completing the procedure was on average 16 months.


  • Approximately 83% of the applications were concluded within 24 months
  • 17% had a completion period duration beyond 24 months

Compare these times to the time periods reported in the first Italian international standard ruling report (74% within 24 months and 26% beyond 24 months). Read TaxNewsFlash-Transfer Pricing (May 2010).

Size of taxpayers

As to the type of applicants, the majority of taxpayers filing for a ruling (approximately 84%) declare a turnover of more than €25 million, and 68% of these are taxpayers with a turnover of more than €100 million.

Pre-filing meetings

As part of the procedure, taxpayers may request one or more preliminary meetings (pre-filing), also on a “no name” basis, in order to seek clarifications on the international ruling procedure.


Among the most recurrent topics under the ruling procedure, transfer pricing ranks first (101 cases out of 134) before dividends, interests and royalties (16 cases).


According to the recent report:


  • From 2009 to 2012, 110 pre-filing procedures have been activated, among which 19 were conducted on a “no name” basis.
  • In 2009 - 13 taxpayers applied for pre-filing meetings.
  • In 2010 and 2011 - 30 taxpayers applied for pre-filing meetings.
  • In 2012 - 37 taxpayers applied for pre-filing meetings.


Contact a tax professional with Kstudio Associato, the KPMG member firm in Italy:


Gianni De Robertis

+39 02 67 64 4912


Maria Eugenia Palombo

+39 06 80 96 3505


Filippo Bertoletti

+39 02 67 64 4897


Or contact a tax professional with KPMG's Global Transfer Pricing Services.




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