RECENT TAX ALERT

Maisto e Associati alongside Solvay Specialty Polymers Italy S.p.A. for the conclusion of the first Italian Patent Box agreement in the chemical industry


19-12-2016
Today, the first advance pricing agreement concerning the definition of the methods of calculation of the qualified income for the purpose of the Italian Patent Box regime has been signed with the Italian Tax Authorities, specifically with the Office for Advance Rulings and International Disputes (Ufficio Accordi Preventivi e Controversie Internazionali).
Maisto e Associati, which concluded the first “international standard ruling” in 2005, has once again confirmed its primary role in the management of the relationships with the Tax Authorities and in the implementation of the new procedures provided for from time to time by the Italian tax Law, providing its professional assistance to the multinational chemical group Solvay.
 
The assistance of Maisto e Associati concerned the management of the APA procedure as a whole, as from the drafting of the request for the access to the Patent Box regime to the management of the discussions with the Office for Advance Rulings and International Disputes aimed at achieving the conclusion of the agreement. In particular, the discussions with Tax Authorities addressed, for the first time, the technical issues relevant to the identification of the qualifying IPs and the expenses directly or indirectly attributable to those IPs as well as the quantification of the income derived from their exploitation according to the OECD transfer pricing methods. It is worth mentioning that Solvay Specialty Polymers Italy S.p.A. stands out as the Italian industrial company which has registered the highest number of new patents to the European Patent Office in 2015.

The professionals of Maisto who supported the company during the procedure are the partners Guglielmo Maisto, Roberto Gianelli and Aurelio Massimiano together with the associates Ernesto Sacchi and Alberto Brazzalotto.