Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
The Italian Revenue Agency has released a new circular clarifying aspects of Italy’s tax credit regime for research and development activities notes Davide Anghileri of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy’s transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy’s patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Davide Anghileri of the University of Lausanne discusses Italy’s January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses the implications of Italy’s decision to put Switzerland on its white list for purposes of the financial transactions tax . . .
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses Italy’s budget 2017, approved by Prime Minister Matteo Renzi’s government October 15, which would lower Italy’s corporate tax rate and add provisions favorable to business . . .
Italy’s tax authorities on September 26 issued a circular clarifying new rules on the deductibility of costs associated with transactions between Italian resident individuals or entities and businesses operating in blacklisted tax haven countries, writes guest author, Davide Anghileri . . .
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses guidance issued by the Italian tax authority on September 16 that provides important details on how to determine if Italy’s controlled foreign company (CFC) tax rules will apply . . .