An interview on Marco Q Rossi & Associati has been published today on the Italian financial newspaper ITALIA OGGI. We attach below the file with the full account: www.lawrossi.com/images/stories/docs/MQR_Italia_Oggi.pdf
Italian Tax Court Rules Against Bank on Tax Abusive Transactions
By Marco Rossi on
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…
Marco Rossi of MQR&A lectured at the Fairfield University International Tax Program
By Marco Rossi on
On July 14, 2010 Marco Rossi presented a lecture on the European Union and EU tax law to candidates/students of Master of Science in Taxation at Fairfield University. We provided an overview of the European Union and its institutions, discussed the sources of EU law and the main developments in the area of EU statutory tax…
EU Outbound Merger Not Eligible For Tax-Free Treatment if No Permanent Establishment in Italy After the Merger
By Marco Rossi on
Italian tax administration rules that EU merger does qualify for tax free treatment under the EU merger directive if no permanent establishment in Italy exists after the merger…
EU Parent-Subsidiary Directive Does Not Apply to Dividends on Shares Held in Usufruct, ECJ Ruled
By Marco Rossi on
The European Curt of Justice ruled that the parent subsidiary directive, which exempts from withholding tax dividends paid from a EU subsidiary to a EU parent, does not apply to dividends paid to the holder of a usufruct right on the shares.…
Withholding Tax on Outbound Dividends to a Luxemburg Investment SICAV Illegal, AG of the ECJ Says
By Marco Rossi on
AG of ECJ issued his opinion in Aberdeen Property Fininvest Alpha, according to which no withholding tax should apply to dividends to a EU company (in the case, a Luxembourg investment fund SICAV) if no similar tax applies to a domestic dividend…
ECJ Ruled That Restrictions to Tax Consolidation Violate EC Treaty
By Marco Rossi on
European Court of Justice in Société Papillon (C-418/07) ruled that French national laws that limit access to tax consolidation in EU cross-border situations violate the EC Treaty. The ruling offers taxpayers opportunities to claim access to consolidation at the EU level every-time that such option is granted at domestic level and to offset losses and profits of the EU members of a consolidated group.…