Tax Alert

• 09-08-2018 TAX ALERT 2018/03
  
  Conversion into Law of Law Decree No. 87/2018: relevant tax measures
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• 28-02-2018 TAX ALERT 2018/02
  
  Public consultation on new Italian TP regulations
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• 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;
  • 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 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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