Italian financial institute, Banca Generali, has signed a agreement with the Italian Revenue Agency, whereby the parties agreed upon the terms and conditions for the settlement of tax claims in relation to transfer pricing for FY 2014 to 2018. Under the agreement, Banca Generali will incur an additional tax charge of €45.99 million for FY 2014-2018. The tax dispute relates to remuneration for a transfer in 2008 of fund management activities in Italian to a newly established Luxembourg company, BG Fund Management Luxembourg S.A. According to the announcement, no penalties will be applied due to the penalty protection regime ... Read more

Bank of Nova Scotia sought to carry back a non-capital loss to offset a transfer pricing adjustment arising from a settlement with Canadian tax authorities. The dispute concerned whether interest on the carryback should run from the date of the written request or the original return filing date. Canada's Tax Court dismissed the appeal in 2021, ruling the deemed payment date was 30 days after the written request, consistent with the unambiguous statutory wording ... Read more