Italian Supreme courts reverses course on the issue of re-characterization of an Italian foreign owned company as permanent establishment of its foreign parent. The decisions seems to depart significantly from previously established case law stemming from the Supreme Court’s decisions in the Philip Morris case and provide more clarity to foreign businesses interested in expanding into Italy
Continue Reading Italian Supreme Court Reverses Course on Permanent Establishment Issue

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
Continue Reading EU Outbound Merger Not Eligible For Tax-Free Treatment if No Permanent Establishment in Italy After the Merger

Italian Regional Tax Court found a Madeira company engaged in the business of purchasing and selling goods had its permanent establishment in Italy and was subject to tax in Italy, were its contracts were negotiated and its business was supervised by its shareholders.
Continue Reading Madeira Company Held Liable to Tax in Italy, Regional Tax Court Ruled