Tax Alert

• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  • 
• 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)
  Continue reading »
  • 
  • 
  • 
• 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
  Continue reading »
  • 
  • 
  •