Italy’s Supreme Court ruled against taxpayer in a case concerning use of fictitious tax residency for tax avoidance purposes. Italy was held to be the real tax residency as the place where taxpayer had maintained his center of main interests
Italy’s Government to Approve New Rules on Transfer Pricing Documentation, Anti Tax Abuse
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.
Italian Prosecutors Obtain the HSBC List
Italian prosecutors have obtained the list of the bank account holders at the Swiss branch of HSBC. The list has been delivered by the French prosecutor and is said to contain 7,000 names of Italian customers with potentially unreported foreign bank accounts. The list includes a total of 120,000 names.
Italy’s Tax Administration Announces More Controls on Nonresidents’ Tax Refunds
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)
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.
Marco Rossi of MQR&A spoke at the 3rd Annual STEP Pacific Rim Conference
Marco Rossi of MQR&A spoke at the 3rd Annual STEP Pacific Rim Conference in Santa Monica, CA on May 6 & 7
Italy Reinforces its Foreign Assets Reporting Rules
Italy’s tax administration issued a guideline according to which all foreign assets must be reported in Italy, including personal assets (such as vacation homes, yachts, jewelery) that do not generate any foreign income taxable in Italy. The new guideline is part of a general reinforcement of foreign assets reporting rules adopted in connection with the enactment of the new tax shield, which enables taxpayers to declare unreported foreign assets and income and pay a reduced tax (4 percent, increased to 5 percent for disclosure returns filed by February 28 and 6 percent for disclosure returns filed by April 30).
E&Y Italian Desk in New York Comments on New US-Italy Treaty
New US-Italy Treaty Commented by E&Y Italian desk in New York
Italy Extends Statute of Limitation for Foreign investments and CFCs
Italy Extends to 9 Years the Statute of Limitation for Income from Foreign Investments and Controlled Foreign Companies
Italy Extends Deadline for Voluntary Compliance Program
Italy Extends Deadlines for Voluntary Disclosure of Undeclared Foreign Assets Program