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 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
Italy issued ruling implementing transfer pricing documentation requirements. Italian transfer pricing documentation framework largely mirrors the EU transfer pricing documentation of conduct and OECD Guidelines. Strict deadlines apply to transfer pricing documentation for 2010 and prior years. Compliance with new transfer pricing documentation requirements allows protection from penalties.
Il giorno 30 Settembre scade il termine per la presentazione della dichiarazione annuale dei redditi delle persone fisiche per l’anno 2009. Contestualmente alla presentazione della dichiarazione annuale dei redditi i contribuenti residenti in Italia che detengono investimenti all’estero devono compilare il modulo RW. Inoltre, nello stesso termine è possibile presentare la dichiarazione integrativa relativa all’anno 2008 e sanare eventuali violazioni degli obblighi di compilazione del modulo RW per il 2008 secondo il meccanismo del ravvedimento operoso con il beneficio della riduzione della sanzione ad 1/10 del minino pari all’1% degli importi non dichiarati.
Italy removed Cyprus and Malta from black list for purposes of CFC rules and Italian rules on tax residency of individuals.
Landi Renzo acquires Baytech, MQR&A acts as legal counsel on the transaction
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.
On February 25, 2010 the European Court of Justice issued its ruling in X Holding (C-337/08 X Holding Judgment.pdf). Under the facts of the case, a Dutch parent wanted to be allowed to combine with its Belgian subsidiary under the Dutch tax consolidation rules to use the latter losses, which it would have been
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 reinforces its anti abuse rules by requiring separate monthly or quarterly disclosure of transaction with foreign enterprises organized in black listed jurisdictions. Deduction of costs and expenses arising from those transactions is denied unless taxpayer proves legitimate business purpose beyond tax saving.