Participation exemption rules do not apply to gains from sale of stock of passive intellectual property holding companies. For the exemption to applies, the company must be engaged in an active licensing business, which includes the active management and development of the intangibles and active licensing to third parties.
Continue Reading No Participation Exemption in the Absence of Active Business

Italy’s Tax Administration in ruling 54 of March 3, 2009 clarified that debt instruments issued by Italian limited liability companies (SRLs) can qualify as debt obligations for tax purposes, and interest paid thereunder can be eligible for the exemption from Italian tax (portfolio interest exemption) fore foreign investors, if the instrument is not part of a permanent establishment of the foreign investor in Italy and the foreign investor otherwise qualifies for the exemption by reasons of being resident or domiciled in an approved jurisdiction (white-listed country).
Continue Reading Italian Tax Administration Clarified Tax Treatment of Debt Obligations Issued by Italian SRL’s