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Tax Alert


  • 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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  • 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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