Tax Alert
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28-02-2018
TAX ALERT 2018/02
Public consultation on new Italian TP regulations -
10-01-2018
TAX ALERT 2018/01
Major tax measures included in the Italian 2018 Budget Law- Amendments to the domestic definition of “permanent establishment”;
- Introduction of a new tax on digital transactions (“Web Tax”);
- Changes to the tax regime of dividends and capital gains from substantial shareholdings;
- Changes to the tax regime of dividends from entities resident in low-tax jurisdictions;
- Changes to the rules limiting the deductibility of interest expenses for corporate tax purposes;
- Changes to the rules governing the interpretation of deeds for Italian registration tax purposes;
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Changes to the VAT group regime.
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12-07-2017
TAX ALERT 2017/03
New Italian rules on tax amnesty for pending litigations and self-disclosure of potential undeclared permanent establishmentsContinue reading »
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
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Transfer pricing rules reshape
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reference to the arm's length principle and internationalbest practices
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specific rules on corresponding adjustments
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10-03-2017
TAX ALERT 2017/01
Implementation decree of Italian CbCR rules publishedHighlights-
Application of CbCR rules as from first reportable period ending on or after 31 December 2016
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Obligations for Italian parents and Italian subs of MNE groups with parents in non-complying States
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Exemption for 2016 for Italian subs with parents in non-complying States in case of voluntary filing by the foreign parent
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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 regimeContinue reading » -
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
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Beneficial impact on penalties and years covered from the stipulation by Italy of a wider network of exchange of information
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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 -
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