Italy–MNE Tax

Europe

Italy makes recent changes to cooperative compliance tax regime

March 28, 2022

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss two significant developments the Italian Revenue Agency made this month to its cooperative compliance regime, a forum allowing a taxpayer to prevent tax audits and to agree in advance with tax authorities regarding the tax treatment of specific uncertain transactions.

Europe

Year-end transfer pricing adjustments and DAC6 obligations in Italy: an additional administrative burden for MNEs?

February 8, 2022

Luca Tortorella, Gatti Pavesi Bianchi Ludovici, discusses the Italian Revenue Agency’s December 31 resolution clarifying that year-end transfer pricing adjustments may be communicated for DAC6 purposes; DAC6 introduces complicated features and adds further reportable obligations.

Czech Republic

Italy’s new clarifications concerning VAT treatment of transfer pricing adjustments

February 1, 2022

Diletta Fuxa, Studio Associato Servizi Professionali Integrati, discusses the Italian tax authority’s December 30 release regarding the VAT treatment of transfer pricing year-end adjustments in its response to . . .

Europe

Italian Revenue Agency provides tax guidance on CFC legislation

January 6, 2022

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss the Italian Revenue Agency’s December 27 release of two documents clarifying the controlled foreign companies (CFC) legislation; the current version of the CFC legislation has been amended by . . .

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Europe

Italy tax agency issues circular on transfer pricing documentation rules

December 9, 2021

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss the Italian revenue agency’s November 26 release of Circular No. 15/E clarifying new instructions relating to amended transfer pricing documentation requirements issued last year that increase the administrative burden on . . .

Americas

India and US agree on transition from India’s ‘equalization levy’ digital tax

November 29, 2021

The US and India have reached a compromise on a transition from India’s “equalization levy” digital services tax towards the terms of the October 8 multilateral agreement on new international taxing rules, according to a November 24 . . .

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

November 23, 2021

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Asia-Pacific

Turkey and US agree on phase-out of digital tax

November 23, 2021

The US Treasury announced on November 22 that it has reached an agreement with the Turkish government on Turkey’s transition from its digital services tax to the new taxing rules under the . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Europe

Italy introduces new patent box regime

October 27, 2021

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss Italy’s October 21 repeal and replacement of the former patent box regime, which, from 2021 onwards, shift it from a profit-based incentive to an extra deduction for certain R&D costs incurred by . . .

Accounting

European digital services taxes to stay for now, with offsetting credits, countries agree

October 21, 2021

Under an October 21 agreement between the United States and Austria, France, Italy, Spain, and the UK, the European countries can keep their existing digital services taxes in place pending implementation of Pillar 1 of the OECD global tax deal; however, multinational groups . . .

Europe

Italy-France tax treaty’s interaction with parent-subsidiary EU directive

October 19, 2021

Michele Targa, Gatti Pavesi Bianchi Ludovici, discusses the Italian Supreme Court’s September 15 decision on the concurrent application of the Italy-France tax treaty and an EU directive to a dividend distribution by a French-resident subsidiary to its Italian-resident . . .

Europe

CJEU to review German transfer pricing obligation: do national tax rules affect EU freedoms?

October 11, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses Germany’s July 15 request that the European Court of Justice review German transfer pricing documentation requirements and associated sanctions in the case C-431/21, X GmbH & Co. v Finanzamt Bremen, following . . .

Europe

Italy draft guidance clarifies transfer pricing documentation requirements

October 5, 2021

Giuliana Polacco, Annarita De Carne, Francesco Drago and Camilla Cominelli, Studio Legale Bird & Bird, discuss the Italian Revenue Agency’s September 20 publication of the draft of a long-awaited circular letter on transfer pricing, focused on the documentation necessary to verify the correct application . . .

Europe

Italian tax agency’s participation exemption interpretation: bull in the china shop

September 16, 2021

Daniele Majorana, Miccinesi Tax, discusses the Italian tax agency’s recent guidance clarifying that the taxable base of the exit tax must be determined on the difference between the market value of the transferred going-concern, considered as a whole, and the tax value of the . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Europe

Italian tax authorities accuse Booking.com of VAT fraud

June 30, 2021

Daniele Majorana, MICCINESI Tax, discusses the Italian finance police’s June 10 announcement of an investigation into whether online travel agency Booking.com evaded payment of around EUR 153 million (USD 182 million) in value-added tax (VAT) . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Europe

EU will propose minimum tax legislation if G20 reaches deal, commissioner says

June 14, 2021

The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Americas

US plans tariffs against six nations as digital tax talks heat up

June 2, 2021

The US Trade Representative on June 2 announced and then immediately delayed implementation of new tariffs on goods from six countries – Austria, India, Italy, Spain, Turkey, and the UK – in response to . . .

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Americas

US agrees to 15% global minimum tax rate, boosting odds for Pillar 2 agreement

May 21, 2021

The US, which has been leading the push for a global agreement on a minimum corporate tax, has proposed a minimum tax rate of 15% – a concession from the 21% rate that the Biden Administration previously . . .

Europe

Italy to introduce 20% R&D credit for work on drugs, including COVID-19 vaccines, if company grants non-exclusive licenses to third-parties: Reuters→

May 20, 2021

Europe

OECD names new chair of international tax policy body

April 19, 2021

The OECD announced on April 16 that it appointed Fabrizia Lapecorella as the new head of the Committee on Fiscal Affairs starting on January 1, 2022. . .

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Europe

G20 ministers renew call for consensus over MNE taxation

April 7, 2021

G20 finance ministers and central bank governors on April 7 renewed their call on for agreement on new tax rules for multinational groups. . .

Digital Economy

New Italian guidance addresses digital service tax details

March 30, 2021

Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan, discuss the Italian Revenue Agency’s long-awaited guidance issued on March 23 clarifying the application and implementation of the digital service tax. . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Digital Economy

Italian digital services tax takes its first steps

January 25, 2021

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the Italian revenue agency’s January 15 release of final guidance on the national digital services tax, provision n. 13185/2021. . .

Europe

New Italian budget law permits advance pricing agreement rollback

January 19, 2021

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a new Italian law related to advance pricing agreements . . .

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Europe

Italy unlocks tax dispute resolution mechanism

January 6, 2021

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 16 Italian tax guidance clarifying changes to Italy’s tax dispute resolution mechanism . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin