Matteo Carfagnini and Marco Poziello comment in the latest issue of Corriere Tributario on some relevant aspects of the “New” Patent Box
In the latest issue of Corriere Tributario (No. 6/2022), Matteo Carfagnini and Marco Poziello analyse – with regard to the “New” Patent Box, under Article 6 of Law Decree No. 146/2021 and subsequent Implementing Provision of the Italian Revenue Agency No. 48243/2022 – the figure of the “investor” and the related concept of “control over risk”, as outlined in the OECD transfer pricing guidelines.