Tax Alert

• 02-01-2019 TAX ALERT 2019/01
  
  Italy implements the ATA Directives in its legal system
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• 28-12-2018 TAX ALERT 2018/05
  

  Law Decree No. 119/2018, providing for favourable settlement procedures, particularly regarding tax claims and debts, converted into Law

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• 05-11-2018 TAX ALERT 2018/04
  
  The Italian Tax Agency clarifies the application of Italian VAT Grouping legislation effective January 1st, 2019
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• 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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