Italy issued circular 58/E with guidance on transfer pricing documentation for multinational companies. The tax administration clarified that failure to file the transfer pricing documentation notice may be considered as a factor to select taxpayer that will be subject to audit
December 2010
Italian Tax Court Rules Against Bank on Tax Abusive Transactions
In a post on December 3, 2010 we reported on a recent ruling issued by the Italian tax court of Emilia Romagna against an Italian banking group in respect of a series of structured finance transactions aimed at obtaining abusive tax benefits (mainly, foreign tax credits under applicable tax treaties).
Based on a copy of…
EU Council of Finance Ministers Adopted New Draft Legislation on Exchange of Tax Information
EU Council of Finance Ministers approved new draft legislation reinforcing exchange of tax information for contrasting tax evasion throughout the EU. The directive shall eliminate the banking secret and ultimately starting from 2015 the exchange of information will be automatic in several areas of tax law which fall within the scope of the directive.…
Italian Tax Court Rules Against Bank on Tax Abusive Transactions
Italian tax court ruled against Italian bank on tax abusive transactions involving use of derivative contracts to generate tax credits and double dips. Italian tax administration wishes to rely on the ruling to resolve similar dispute with other banks. The total amount of income that can be recaptured is around three billion with an additional tax in excess of one billion plus interest and penalties. Additional comments on the ruling will follow on our blog…