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…
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.
Continue Reading New Law Requires Additional Disclosure of Abusive Transactions