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

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.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-01-22
DOI
https://doi.org/10.59403/1svs9dt
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

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

S. Zucchetti, FredC. Johnson, Sero Mazzone, Tommaso Marchetti
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

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

S. Zucchetti, FredC. Johnson, Sero Mazzone, Tommaso Marchetti
article en

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.

International Transfer Pricing JournalVol. 33(1)
Openalex Percentile: Top 80%
Corporate Taxation and Avoidance
DOISourceOpenAlex
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Bilateral Advance Pricing Agreements under Article 25 of the Italy-United States Double Taxation Treaty: Legal Frameworks, Procedures and Emerging Challenges — S. Zucchetti, FredC. Johnson, et al. · International Transfer Pricing Journal (2026) | TGRS Research Map | TGRS