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  • 17-01-2018 EU TAX ALERT 2018/01
    Case C-650/16, Bevola

    AG Campos Sánchez-Bordona issued his opinion on the compatibility with the freedom of establishment of the Danish legislation precluding the deductibility in Denmark of final losses incurred by foreign PEs
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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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  • 20-12-2017 EU TAX ALERT 2017/08
    The CJEU confirms that (i) TP adjustments are not relevant for declaring import taxable base of goods (Case C-529/16 Hamamatsu Photonics Deutschland GmbH) and that (ii) general presumptions of fraud and abuse are not compatible with the Parent Subsidiary Directive and the freedom of establishment (Joined cases C-504/16 Deister Holding and C-613/16 Juhler Holding)
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  • 14-12-2017 EU TAX ALERT 2017/07
    Case C-382/16 Hornbach-Baumarkt

    AG Bobek issues his opinion on compatibility of German transfer pricing legislation with the freedom of establishment
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  • 05-12-2017 EU TAX ALERT 2017/06
    The ECOFIN approved (i) the EU list of non-cooperative jurisdictions in taxation matters and (ii) the conclusions on the taxation of profits in the digital economy
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  • 27-11-2017 EU TAX ALERT 2017/05
    The CJEU ruled on the interpretation of Art. 90 of VAT Directive concerning “VAT on bad debt relief” and the relevant Italian Implementing provision (Case C-246/16 Enzo Di Maura)
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  • 23-11-2017 EU TAX ALERT 2017/04
    The Court of Justice of the European Union (“CJEU”) ruled on (i) the immediate taxation of gains from the transfer of a foreign PE (Case C-292/16 A Oy) and (ii) the direct applicability of the general principle of prohibition of abuse to EU secondary tax legislation (Case C-251/16 Cussens)
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  • 15-11-2017 EU TAX ALERT 2017/03
    Joined cases C-327/16 (Jacob) and C-421/16 (Lassus)

    AG Wathelet issues his opinion on compatibility of the French deferred taxation system for exchanges of shares with the EU Merger Directive and the freedom of establishment
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  • 09-11-2017 EU TAX ALERT 2017/02
    Joined cases C-236/16 and C-237/16; C-233/16 and joined cases C-234/16 and C-235/16 - ANGED

    AG reiterates that the reference system for State aid analysis varies according to the difference in treatment concerned
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  • 26-10-2017 EU TAX ALERT 2017/01
    Case C- 39/16 - Argenta Spaarbank NV v. Belgische Staat

    The Court of Justice declares incompatibility with the Parent Subsidiary Directive of rules limiting interest deduction for the Parent to the extent of dividends received
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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


    • 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

    • 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

    • 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
    • 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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  • 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
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  • 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
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  • 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
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  • 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
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  • 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
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  • 30-01-2015 TAX ALERT 2015/01


    • 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
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  • 31-12-2014 TAX ALERT 2014/12


    • 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
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  • 28-11-2014 TAX ALERT 2014/11


    • 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)
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  • 31-10-2014 TAX ALERT 2014/10


    • 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
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