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Taxand Global Guide to M&A Tax 2022 We are delighted to present the latest edition of the Taxand Global M&A Tax Guide to equip you with tax reference points relevant to mergers and acquisitions, including recent local tax developments. Read more

On 21 June 2022, the Government approved the Law Decree 73/2022 (hereinafter the “Decree”) providing for some simplification in tax law. Below the analysis of the main tax measures. Art. 3 – Tax deadlines With art. 3 of the Decree, the Government approved some changes in deadlines of tax fulfillments. The most relevant changes regard: […]

International Tax Insider No. 1/2022 – Private equity and beneficial ownership: will the Italian Supreme Court confirm a look-through approach? On 3 February 2022, the Second-Degree Tax Court of Milan issued a decision on a case dealing with interest payments by an Italian company to its Luxembourg parent company in the context of a foreign […]

An ITR-TP Special Focus Stefano Bognandi and Elena Baron of LED Taxand considers recent Italian case law and compliance with the arm’s-length principle. On May 20 2021, the Italian Supreme Court (Italian Supreme Court, decision No. 13850/2021) was called to decide upon a dispute concerning the compliance with the arm’s-length principle – stated by Article […]

On 3 February 2022, the Second-Degree Tax Court of Milan issued a decision on a case dealing with interest payments by an Italian company to its Luxembourg parent company in the context of a foreign investment fund structure. In particular, the Second-Degree Court ruled that (i) the WHT exemption granted by the Interest and Royalty […]

Real Estate Tax Insider no 4/2021 – 4Q 2021 Italian Real Estate Tax News HOME PROFILE TEAM EXPERTISE MULTIMEDIA CONTENT BLOG & NEWSLETTER WORK WITH US BROCHURES Skip to content Real Estate Tax Insider no 4/2021 – 4Q 2021 Italian Real Estate Tax News LED Taxand summarizes hereinafter the main tax news regarding Italian real […]

he Italian Revenue Agency (the “IRA”) released for public consultation until October 12, 2021, the draft circular letter (the “Circular”) containing clarifications on the correct application of the transfer pricing documentation rules (the “TP documentation”) contained in the Administrative Provision n. 360494 of November 23rd, 2020 (the “Provision”). The preparation of the documentation serves to […]

Italian Transfer Pricing documentation – New measure and recent clarifications released Introduction On September 20th, 2021, the Italian Revenue Agency (the “IRA”) released for public consultation until October 12, 2021, the draft circular letter (the “Circular”) containing clarifications on the correct application of the transfer pricing documentation rules (the “TP documentation”) contained in the Administrative […]

Italian Transfer Pricing Documentation in Light of the Circular Letter No. 15/E/2021 Introduction On November 26th, 2021, the Italian Revenue Agency (the “IRA”) published, following the public consultation time frame, the Circular Letter no. 15/E (the “Circular”) providing clarifications on transfer pricing documentation (the “TP Documentation”) rules contained in the Administrative Provision n. 360494 of […]

Real Estate Tax Insider No. 3/2021 – 3Q 2021 Italian Real Estate Tax News EU Court of Justice, Case C-931/19 – Letting a property in a Member State does not give rise to a fixed establishment for VAT purpose if the owner does not have his or her own staff to perform services relating to […]

New measure and recent clarifications released Introduction On September 20th, 2021, the Italian Revenue Agency (the “IRA”) released for public consultation until October 12, 2021, the draft circular letter (the “Circular”) containing clarifications on the correct application of the transfer pricing documentation rules (the “TP documentation”) contained in the Administrative Provision n. 360494 of November […]

Introduction On September 20th, 2021, the Italian Revenue Agency (the “IRA”) released for public consultation until October 12, 2021, the draft circular letter (the “Circular”) containing clarifications on the correct application of the transfer pricing documentation rules (the “TP documentation”) contained in the Administrative Provision n. 360494 of November 23rd, 2020 (the “Provision”). The preparation […]

ITR M&A Special Focus With the Principle of Law No. 10/2021, the Italian tax authorities dealt with the computation of the taxable base for exit tax purposes in cases where the going concern transferred includes participations that, in principle, may benefit from the participation exemption (PEX) regime. The Italian tax authorities reached the conclusions that […]