The Italian Supreme Court, with its ruling n. 8196 of April 22, 2015 held that a NY corporation, wholly owned by an Italian company, and effectively managed and controlled by its Italian shareholders and directors in Italy, had to be treated as an Italian resident company for Italian tax purposes, and was subject to corporate
Italy’s enacted a new tax on real estate properties located outside of Italy. The tax is charged at 0.76 percent rate on purchase price of fair market value. Individual taxpayers owning foreign real property directly are liable for the tax. Apparently, the tax does not apply to real property owned indirectly through foreign investment or management companies.
Continue Reading Italy’s New Tax on Foreign Real Estate Property
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…