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July 24, 2026International Transfer Pricing Journal0 citations

Home Office and Senior Executives: Navigating Permanent Establishment and Transfer Pricing Risks

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FCFilippo CalatroniKSKatia Scordia

Key Points

  • The article aims to analyze how updates to the OECD Commentary influence the assessment of home office permanent establishments for senior executives in Italy.
  • Examined the 2025 update to the OECD Commentary on Article 5.
  • Analyzed the interaction between the temporal threshold and the commercial reason test.
  • Considered the implications of Italy’s inbound workers regime on transfer pricing.
  • Identified key changes in the analysis of home office permanent establishments.
  • Outlined potential transfer pricing consequences arising from the existence of a PE.
  • Highlighted the importance of adapting to new guidelines for compliance in Italy.

Abstract

This article examines how the 2025 update to the OECD Commentary on article 5 reshapes the analysis of home office permanent establishments (PEs) for senior executives working remotely from Italy. It considers the interaction between the new temporal threshold and commercial reason test, Italy’s inbound workers regime and the transfer pricing consequences that may arise once a PE is found to exist.

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Cite This Study

Calatroni et al. (2026) studied this question.

synapsesocial.com/papers/6a6300f2395161722cd15ab0https://doi.org/10.59403/23z70d9
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