With its tax ruling n. 88/E of October 18, 2019 (Ruling 88-2019), the Italian Tax Agency denied the interest withholding tax exemption provided for in the EU Interest and Royalties Directive, in respect of interest due by an Italian Target on a shareholder’s loan extended from its EU Parent in connection with a
Holding Company’s Tax-Free Reorganization Does to Jeopardize Dividend Withholding Exemption, Italy’s Tax Agency Rules
In its Ruling N. 380 of September 11, 2019, Italy’s Tax Agency provided its guidance on certain tax implications of a corporate reorganization pursuant to which a Luxembourg holding company, which owns an Italian company, would reincorporate into Switzerland and convert into a Swiss tax resident company.
Prior to the reincorporation of the holding
Italian Tax Agency Rules on Tax Effects of Early Termination of Trust, Treats It As Gift Back to Settlor Subject to Gift Tax
In its Private Letter Ruling n. 355 of August 30, 2019 the Italian Tax Agency considered the tax implications, for Italian gift tax purposes, of a transaction involving the early termination of an irrevocable trust by way of mutual consent of the trustee, settlor and beneficiaries of the trust, with a return of the trust’s
Italian Tax Residence For Individuals: A Refresher And Look At Open Issues And New Matters
Italian tax residence is a very important topic for foreign nationals who travel regularly to Italy, own houses and spend significant time with their family there, while living and working abroad, as well as for those who relocate to Italy and work, do business or just retire there.
For the former, it may be surprising
Italian Substituted Tax On Financial Income At Odds With Tax Treaties
Italy taxes various categories of financial income – namely dividends, interest and capital gains – earned by private investors outside the carrying on of a trade or business, by way of a substitute tax charged on the gross amount of the income at the flat rate of 26 percent.
With effect from January 1, 2018,
The Italian Tax Agency Clarifies The Meaning of Beneficial Owner For Purposes of International Tax Reporting of Foreign Assets Held in Trust
With its resolution n. 53/E issued on May 29, 2019 the Italian tax agency issued some important clarifications on the exact scope of the Italian international tax reporting rules in case of foreign assets held through trusts, foundations or similar entities.
In particular, the ruling focuses upon the interpretation of the term “beneficial owner”, which
Italian Tax Court Rules Against The Use Of Unit Link Insurance Policy For Tax Avoidance Purposes
With its decision n. 5608 of December 10, 2018 the Italian Provincial Tax Court of Milan ruled against the (ab)use of so called “unit linked” life insurance policies for tax avoidance purposes.
The decision of the tax court refers to the latest rulings of the Supreme Court on the matter and represents a significant step
Italian Tax Agency, Taxpayer Settled The Biggest “Silent” Permanent Establishment Tax Case For a Record Amount of 1.250 Billion Euro In Taxes And Penalties
The Italian financial newspaper “Il Sole 24 Ore” reported today that Koering, the French-owned conglomerate which controls some of the most renowned and revered luxury brands in the world, such as Gucci, Bottega Veneta, Saint Laurent, Pomellato and others associated to clothing, jewelry, bags and other luxury products, settled a tax case with the Italian
Italy’s Regional Tax Court Denies Dividend Withholding Tax Exemption In the Absence Of Actual Taxation In the Country of Residence
By way of ruling n. 55/6/2019 filed on January 21, 2019, the Regional Tax Court of Abruzzo held that no withholding tax exemption under the EU Parent-Subsidiary Directive applies, unless the EU parent company proves that it has been “materially charged” with an income tax on the dividends in its own country of residency.
The
Italy Enhances Special Tax Regime For Foreign High Skilled People and Entrepreneurs
In 2015, Italy enacted a special tax regime for high skilled workers who move to Italy to work there for an Italian employer, on assignment to an Italian affiliate of a foreign multinational, or on their own as independent consultants and service providers. Eligible taxpayers (who include Italian citizens, and foreign nationals who are citizens