What question did this study set out to answer?

To evaluate the legal frameworks and procedures of bilateral advance pricing agreements between Italy and the US.

January 26, 2026

Bilateral Advance Pricing Agreements under Article 25 of the Italy-United States Double Taxation Treaty: Legal Frameworks, Procedures and Emerging Challenges

SZS. ZucchettiNational Agency for New Technologies, Energy and Sustainable Economic Development FJFredC. Johnson TMTommaso Marchetti

Key Points

To evaluate the legal frameworks and procedures of bilateral advance pricing agreements between Italy and the US.
Overview of legal frameworks for BAPAs
Examination of procedures involved in BAPAs
Analysis of strategic significance for multinational enterprises
BAPAs provide legal certainty for multinational enterprises
They help prevent double taxation
Effective cooperation between tax authorities is enhanced

Abstract

This article provides an overview of bilateral advance pricing agreements between Italy and the United States, examining their legal frameworks, procedures, and strategic significance for multinational enterprises. It highlights how BAPAs serve as robust instruments for ensuring legal certainty, preventing double taxation and fostering effective cooperation between tax authorities in cross-border transfer pricing matters.

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