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.
International Taxation
Italy’s Tax Administration Announces More Controls on Nonresidents’ Tax Refunds
By Marco Rossi on
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)
By Marco Rossi on
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.…
E&Y Italian Desk in New York Comments on New US-Italy Treaty
By Marco Rossi on
New US-Italy Treaty Commented by E&Y Italian desk in New York…
New Italy-U.S. Tax Treaty Enters Into Force
By Marco Rossi on
The New U.S.-Italy Tax Treaty entered into force on December 16, 2009.…
OECD Releases Report on Granting of Treaty Benefits with Respect To The Income of Collective Investment Vehicles
By Marco Rossi on
The OECD Committee on Fiscal Affairs has released as a discussion draft a Report on “The Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles”(PDF) which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the question of the extent to which either collective investment vehicles (CIVs) or their investors are entitled to treaty benefits on income received by the CIVs. The Report is a modified version of the Report “Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles” (PDF) of the Informal Consultative Group on the Taxation of Collective Investment Vehicles and Procedures for Tax Relief for Cross-Border Investors (“ICG”) which was released on 12 January 2009. In that original Report, the ICG addressed the legal and policy issues specific to CIVs and formulated a comprehensive set of recommendations addressing the issues presented by CIVs in the cross-border context.