Executive summaryOn 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 EU (DAC6) followed by the Decree of 17 November 2020. The Resolution clarified that a TP policy implemented by a group of companies may satisfy the definition of a cross-border arrangement and, as such, may be subject to the MDR regulation. Furthermore,...