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Archive for Italy Tax

Italian Tax Code: Economic Nexus Rule And Changes To Permanent Establishment

With the Budget Law for 2018 (Law n. 205 of December 27, 2017), Italy amended the definition of the term “permanent establishment” set forth in article 162 of the Italian Tax Code.

The term permanent establishment now covers situations in which a foreign enterprise does not have a physical nexus with Italy, but it has a regular and continuous economic presence in the country; engages in ancillary activities that are an essential component of its core business, or operates through commissioners or other agents who do not enter into contracts in the name of the enterprise, but procure the conclusion of contracts that are eventually signed by the principal with no material modifications. Read more

U.S. Impact Of Federal Tax Reform From Italy’s Perspective: Renewed Attention On Italy’s Anti Inversion Rules

As a result of the significant reduction of U.S. corporate income tax rates pursuant to the tax reform of the TCJA enacted on December 22, 2017, the Unites States now has a lower corporate tax rate than many of its trading partners, meaning that, in many instances, the profits of foreign owned or controlled-U.S. subsidiaries shall be taxed more favorably than the profits of their foreign parent companies or affiliates in their home jurisdictions. That creates an incentive for foreign companies to channel more profits through their U.S. subsidiaries, in order to benefit from lower U.S. income taxation compared to that applicable in the parent company’s home country. Read more

Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the sixth of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Individual taxation – Step-up of tax value of non-substantial participations in unlisted Italian companies

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Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the fifth of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Individual taxation – Regime applicable to dividends and capital gains derived from individuals outside a business capacity

The current tax regime applicable to dividends and capital gains, realized by individuals acting as non-entrepreneurs, depends foremost from the type of qualification that the holding assumes in the hand of the individual. Read more

Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the fourth of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Individual taxation – Modification of black-list criteria for CFC purposes: taxation of profits accrued and distributed in different fiscal periods and under different rules Read more

Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the third of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Corporate taxation – Partial exemption of dividends distributed by CFCs.

According to current Italian rules, profits realized by non-resident subsidiaries are deemed to exist under the CFC legislation (article 167(4) of the ITA) if the relevant nominal rate in the foreign jurisdiction (other than EU and EEA countries) is lower than 50% of the combined IRES tax (rate 24%) and IRAP tax (rate 3,9%). Read more

Budget Law For 2018 Introduces Major Developments To Domestic Tax System- Part II

This is the second of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018)

Corporate taxation – Changes to calculation of EBITDA for deduction of any excess of interest expenses Read more

Italy – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

The Italian 2018 Budget Law, approved by the Parliament on 23 December 2017 and turned into Law No. 205 of 27 December 2017, has introduced a package of tax reforms for corporations and individuals.

This is the first of a series of posts on the major developments introduced by Law No. 205. In each post is provided a general overview of a specific tax reform.

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