Faedda, Francesca (2015) Profili fiscali della valorizzazione dei beni nelle operazioni straordinarie. Doctoral Thesis.
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The aim of this work is to determine the effects on taxation tied to assets valuation on the occasion of business combinations.
In order to study this topic properly, after a quick view of the most popular firm evaluation methods, it has been examined how to account this kind of operations using both national and international accounting standards, giving special attention to business combinations under common control. The study of business combinations accounting methods is fundamental because the value and the way assets appear in the balance sheet affects directly tax revenue accordingly to Italian tax law.
Therefore, it has been pointed out the tax relevance of capital gains arising from business combinations such as mergers, demergers or transfers of companies, and how these operations have effects on indirect taxes like registration fee and mortgage and cadastral taxes.
Afterwards, it has been examined the assessment power held by tax agencies in order to contest the determination of assets value made by taxpayers and especially the transfer pricing aspects of business restructurings carried out by associated enterprises. From this study emerged several coordination problems among domestic tax law and international transfer price guidelines issued by OECD.
At last, it has been provided to highlight any similarities and differences between value configurations encountered during the dissertation, such as cost, sum due, normal value, fair value and valuations at arm’s length.
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