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TAX ALERT


  • 12-07-2017 TAX ALERT 2017/03
    New Italian rules on tax amnesty for pending litigations and self-disclosure of potential undeclared permanent establishments

    Highlights

    • Tax Amnesty: Possibility to settle pending tax litigations with a forfeiture of 100% of penalties
    • Disclosure of potential undeclared permanent establishments: application of 50% of minimum penalties and non-application of criminal penalties
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  • 27-04-2017 TAX ALERT 2017/02
    Carried interest schemes and transfer pricing: new rules enacted by the Italian Government

    Highlights
    • New rules introduced for qualifying carried interest schemes
      • minimum 1% investment
      • 5-year minimum holding period
    • Transfer pricing rules reshape
      • reference to the arm's length principle and internationalbest practices
      • specific rules on corresponding adjustments
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  • 10-03-2017 TAX ALERT 2017/01
    Implementation decree of Italian CbCR rules published

    Highlights
    • Application of CbCR rules as from first reportable period ending on or after 31 December 2016
    • Obligations for Italian parents and Italian subs of MNE groups with parents in non-complying States
    • Exemption for 2016 for Italian subs with parents in non-complying States in case of voluntary filing by the foreign parent
    • CbCR to be used by tax authorities as an indicator to start further enquiries on transfer pricing
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  • 28-12-2016 TAX ALERT 2016/06
    Italy introduces VAT Group regime
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  • 09-12-2016 TAX ALERT 2016/05
    • Regime available to individuals transferring their residence to Italy (after a 9 out of 10 period of residence abroad)
    • Flat taxation of foreign-source income (€ 100,000)
    • Possibility to extend the benefit to relatives
    • Exemption from reporting obligations, inheritance / gift taxes and wealth taxes
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  • 07-11-2016 TAX ALERT 2016/04
    VOLUNTARY DISCLOSURE 2.0: NEW EDITION
    • Deadline for access to the voluntary disclosure programme extended to 31 July 2017
    • Beneficial impact on penalties and years covered from the stipulation by Italy of a wider network of exchange of information
    • Possibility to choose between self-calculation and preliminary review by tax authorities
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  • 04-07-2016 TAX ALERT 2016/03
    Brexit: potential consequences on the tax relations between the UK and Italy
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  • 07-04-2016 TAX ALERT 2016/02
    • Increased certainty on interest deductibility in LBO transactions
    • Tax authorities’ attention on fees charged by private equity funds to portfolio companies
    • Clarifications on interest withholding taxes in cases of indirect lending
    • Increased attention on use of foreign vehicles reduction of corporate income tax rate
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  • 01-02-2016 TAX ALERT 2016/01
    • Reduction of corporate income tax rate
    • Review of statute of limitation rules
    • Abolition of “black list cost” rules
    • Country-by-Country Reporting rules
    • New incentives introduced
    • New penalty system entering into force as from 2016
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  • 27-10-2015 TAX ALERT 2015/05

    Last set of decrees implementing the 2014 Italian Tax Reform

    • Reform of tax ruling procedures
    • Review of tax litigation
    • Review of the administrative penalty system
    • Review of the criminal penalty system
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  • 23-04-2015 TAX ALERT 2015/04
    • Changes to rules on taxation of crossborder relationships
    • New definition of “abuse of law”
    • Review of statute of limitations
    • Cooperative compliance program
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  • 07-04-2015 TAX ALERT 2015/03
    • Review of the black lists announced
    • Amendments to the recently introduced Patent Box regime
    • Extension of the interest withholding tax exemption for qualifying foreign lenders
    • Supreme Court judgments on the application of gift tax to trusts
    • Foreign tax credit: clarifications provided by the Italian tax authorities
    • Extension of reverse brain drain incentive
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  • 06-03-2015 TAX ALERT 2015/02
    • Amending Protocol to Italy and Switzerland on exchange of information
    • Exchange of Information Agreements also with Liechtenstein, Monaco, Guernsey and Isle of Man
    • Constitutional Court declares Robin Hood Tax illegitimate
    • Business Restructurings qualified by the Supreme Court as transfers of going concern
    • Supreme Court case law on substitute tax for refinancing transactions
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  • 30-01-2015 TAX ALERT 2015/01

    Highlights

    • Increase of taxation for Italian pension funds
    • Tax step-up election for shares held by individuals
    • Redesign of the "blacklists"
    • San Marino now white-listed
    • New rules applicable to liquidated companies
    • Broadening of possibilities to cure past violations
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  • 31-12-2014 TAX ALERT 2014/12

    Highlights

    • Applicability of voluntary disclosure programme as of 1 January 2015
    • Ordinary taxation of disclosed income, but significant reductions of penalties and removal of criminal charges
    • Luxembourg removed from black-list
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  • 28-11-2014 TAX ALERT 2014/11

    Highlights

    • Improvements to the SIIQ regime become law
    • New law enacted to remove EU law infringements
    • Qatar included in the white list
    • Transfer pricing audits on multinationals: Proposed actions by the Italian Joint Stock Company Association (ASSONIME)
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  • 31-10-2014 TAX ALERT 2014/10

    Highlights

    • New "patent box" regime
    • Increase of IRAP tax rate
    • Deductibility of labour costs for IRAP purposes
    • Higher taxation of dividends received by non-commercial entities
    • Limitation of exemption for life insurance policies
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