The objection raised
in terms of transfer pricing was deemed illegitimate, as the Italian tax
authority was not able to prove that transfer pricing was used to shift the tax
base to countries with a lower tax rate than Italy. This ruling confirms that
transfer pricing is a useful tax evasion tool and is in line with previous
rulings by the Supreme Court (e.g. Supreme Court ruling no. 22023/2006, Supreme
Court ruling no. 7343/2011, Supreme Court ruling no. 9709/2015 and Supreme Court
ruling no. 15642/2015) (Milan tax appeal court ruling no. 1028/6/17 of 10 March
2017).