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
International Taxation
Italian Taxation of Collective Investment Vehicles and Treaty Benefits
By Marco Rossi on
Mutual funds give investors an opportunity to participate in diversified investment holdings and access to professional managent on the face of a relatively small investment.
The Italian tax treatment of domestic mutual funds is designed to provide portfolio investors with the same tax treatment they would receive if they owned directly the same investments that…
Marco Rossi of MQR&A Spoke at Chartered Institute of Taxation’s Meeting in Milan
By Marco Rossi on
Marco Rossi was one of the speakers at the meeting organized by the Chartered Institute of Taxation in Milan on October 15, 2010. Marco presented on transfer pricing documentation requirements from the perspective of the United States and regional organizations such as PATA, EU and OECD. Italy recently enacted its own rules on transfer pricing…
OECD Issued Report on Granting of Treaty Benefits In Respect of Income of Collective Investment Vehicles
By Marco Rossi on
On 31 May 2010 the OECD Committee on Fiscal Affairs released a Report on “The Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles”. The Report contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the question of the extent to which either collective investment vehicles (CIVs) or their investors are entitled to treaty benefits on income received by the CIVs. These changes are expected to be included in the 2010 Update to the Model Tax Convention (the draft contents of which were released on 21 May 2010) and the Report would then be included in volume II of the loose-leaf and electronic versions of the Model.
Marco Rossi of MQR&A lectured at the Fairfield University International Tax Program
By Marco Rossi on
On July 14, 2010 Marco Rossi presented a lecture on the European Union and EU tax law to candidates/students of Master of Science in Taxation at Fairfield University. We provided an overview of the European Union and its institutions, discussed the sources of EU law and the main developments in the area of EU statutory tax…
Italy’s Government to Approve New Rules on Transfer Pricing Documentation, Anti Tax Abuse
By Marco Rossi on
A decree presented to the Italian Council of Ministers today will introduce new provisions on contemporaneous documentation for transfer pricing purposes and a new black list with a duty to disclose any transaction carried out in or with any black listed countries to the tax administration. Also, the minimum threshold for the duty to report cross border transfers of money will be reduced to euro 5,000.…
Italy’s Tax Administration Announces More Controls on Nonresidents’ Tax Refunds
By Marco Rossi on
Italy’s tax administration announced stricter controls on tax refund applications filed on behalf of nonresident persons, and sent a notice to various banks acting as intermediaries in which it requested more information in order to avoid abuse and treaty shopping. As a result, banks may be compelled to identify and disclose information about clients and final beneficiaries of the refund.…
Italy’s Tax Administration Published Report on Italian International Tax Ruling (APA)
By Marco Rossi on
Italy’s tax administration published its report on Italian international tax ruling showing 52 applications and 19 agreements signed in the first five years of the program, half of which by foreign multinational enterprises.…
E&Y Italian Desk in New York Comments on New US-Italy Treaty
By Marco Rossi on
New US-Italy Treaty Commented by E&Y Italian desk in New York…
New Italy-U.S. Tax Treaty Enters Into Force
By Marco Rossi on
The New U.S.-Italy Tax Treaty entered into force on December 16, 2009.…