Year-End Adjustments and GloBE Implications: Italian and US Perspectives

This article examines the treatment of year-end transfer pricing adjustments under the GloBE rules, comparing Italian and US approaches and highlighting the asymmetries that arise when adjustments are recognized only for tax purposes. It analyses how these discrepancies affect GloBE Income, covered taxes and the effective tax rate; and it discusses the resulting risks of double taxation or non-taxation. The authors propose clarifications and solutions, including alignment mechanisms and recent developments under the Side-by-Side (SbS) package.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-05-01
DOI
https://doi.org/10.59403/3j27d4k
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Year-End Adjustments and GloBE Implications: Italian and US Perspectives

Palesa Sansole, Giulio Tombesi
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Year-End Adjustments and GloBE Implications: Italian and US Perspectives

Palesa Sansole, Giulio Tombesi
article en

Abstract

This article examines the treatment of year-end transfer pricing adjustments under the GloBE rules, comparing Italian and US approaches and highlighting the asymmetries that arise when adjustments are recognized only for tax purposes. It analyses how these discrepancies affect GloBE Income, covered taxes and the effective tax rate; and it discusses the resulting risks of double taxation or non-taxation. The authors propose clarifications and solutions, including alignment mechanisms and recent developments under the Side-by-Side (SbS) package.

International Transfer Pricing JournalVol. 33(3)
No poverty
Openalex Percentile: Top 7%
Corporate Taxation and Avoidance
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Year-End Adjustments and GloBE Implications: Italian and US Perspectives — Palesa Sansole, Giulio Tombesi · International Transfer Pricing Journal (2026) | TGRS Research Map | TGRS