Executive summary

On 31 December 2021, the Italian Tax Authorities published Resolution No. 78/2021 (the Resolution) on the correct interpretation of transfer pricing (TP) adjustments between associated entities for the purposes of the Mandatory Disclosure Rules (MDR) under Legislative Decree No. 100, of 30 July 2020, which transposed the European Union (EU) Directive 2018/822 of the Council of the…