Italy–MNE Tax

Digital Economy

Italian digital services tax is knocking at the door

January 6, 2021

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 17 guidance issued by the Italian tax authority that addresses Italy’s new digital service tax . .

Europe

EU Commission asks Italy to end corporate tax exemptions for ports, concludes rules grant illegal State aid: EU Commission→

December 7, 2020

Europe

Italy updates transfer pricing regulations

December 7, 2020

Angela Valente, Diego Conte, and Alessandro Foti of De Berti Jacchia, Milano, discuss Italian transfer pricing documentation regulations issued on November 23 that, among other things, address low-value-added services, new signature requirements, and the definition of small and medium-sized entities . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Europe

EU court rules Romania can impute interest on intercompany loans, but what should the rate be?

November 4, 2020

Dr. Harold McClure, a New York City economist, notes the EU Court of Justice’s October 8 ruling confirming that Romania’s tax authority can require arm’s length interest rates on intercompany loans and discusses how one would determine the interest rate . . .

Americas

The transfer pricing implications of Armani’s US advertising payments

September 17, 2020

New York City economist Dr. Harold McClure discusses a difficult transfer pricing issue often faced by multinational apparel and shoe manufacturers, namely, how to treat locally incurred advertising expenses where the foreign parent formally owns the trademarks . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Europe

Italy enacts DAC6 directive into law effective August 26: Giorgio Vaselli / Withersworldwide→

August 21, 2020

Asia-Pacific

UK guidance updated to state that France, Italy, Malaysia, Turkey taxes are similar to UK’s digital services tax for purposes of cross-border relief: HM Revenue and Customs→

August 5, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Europe

Italy clarifies VAT reporting obligations of online marketplaces

June 16, 2020

Davide Anghileri, a tax researcher with the University of Lausanne, Switzerland, discusses June 1 Italian Revenue Agency guidance clarifying the VAT reporting obligations of online platforms . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Italy’s Supreme Court rules on VAT treatment of intercompany management fees

May 21, 2020

Gian Luca Nieddu, Partner, Transfer Pricing & Tax Value Chain, Hager & Partners, Milan area, discusses a recent decision, of Italy’s Supreme Court which addressed the VAT deductibility of intercompany charges accomplished by the reverse charge mechanism . . .

Europe

EU court rules on legality Italy-Portugal tax treaty’s pension taxation scheme

May 18, 2020

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the European Court of Justice’s April 30 decision addressing a challenge to the legality of the pension scheme under the double taxation convention between Italy and Portugal . . .

Europe

Italy’s financial transaction tax complies with EU law, court rules

May 13, 2020

Francesca Amaddeo a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, analyzes a long-awaited decision of the European Court of Justice, released on April 30, that concludes Italy’s financial transaction tax on derivatives of equity transactions is compatible with EU law . . .

Europe

Taxation of cross-border workers in southern Switzerland uncertain during COVID-19 pandemic

April 29, 2020

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland writes that the taxation of many of the almost 70,000 Italians that formerly crossed the border to work in Switzerland is now uncertain given changes made in response to COVID-19 . . . .

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Europe

Italian politicians rebuke Netherlands over opposition to EU emergency aid, say Dutch corporate tax regime siphoned money away from EU states that could have helped: Zack Newmark / NL Times→

March 31, 2020

Europe

Italy enacts tax relief to cushion Coronavirus emergency

March 2, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses emergency tax measures enacted by Italy’s Council of Ministers yesterday evening that are aimed at reducing the economic harm caused by the Coronavirus. . .

Digital Economy

Italy adopts digital services tax, notional interest deduction

January 8, 2020

MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, Switzerland, discusses Italy’s 2020 budget law, which includes several tax provisions of interest to multinational enterprises investing in Italy . . .

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

US trade officials propose tariffs of up to 100 percent on French goods to counter digital services tax

December 2, 2019

The office of the United States Trade Representative (USTR) today proposed retaliatory tariffs of up to 100 percent on French wine, cheese, handbags, makeup, china, and similar items, after concluding that France’s digital services tax . . .

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Digital Economy

Italy’s Council of Ministers make last-minute changes to draft of Budgetary Law 2020

October 23, 2019

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland, writes about Italy’s Budget Plan 2020 and related measures, passed by the Council of Ministers with last-minute changes, which includes a digital services tax, environmental and sugar taxes, and measures to thwart tax evasion . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Digital Economy

Italy still plans to implement 3 percent “web tax” on large digital firms in 2020, minister says: Giuseppe Fonte / Reuters→

October 15, 2019

Digital Economy

Italy probing whether infrastructure used by Netflix constitutes a PE: Stuart Thomson / Digital TV Europe→

October 3, 2019

Europe

Italian Revenue clarifies new reporting option for patent box tax benefit

October 1, 2019

Gian Luca Nieddu, Head of Transfer Pricing and Tax Value Chain at Hager & Partners, Milan area, writes about Italy’s September 9 clarifications to the patent box regime . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

Italy clarifies interaction of patent box regime and foreign tax credit

June 10, 2019

Davide Anghileri of the University of Lausanne discusses clarifications made by the Italian revenue agency on May 28 concerning the interaction of the Italian patent box regime the foreign tax credit. . .

Ten EU states considering German plan for .2% tax on purchases stock in EU headquartered companies: Reuters→

June 17, 2019

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Europe

Takeaways from Italy’s new transfer pricing country profile

June 28, 2019

Gian Luca Nieddu of Hager & Partners, Milan area, Italy, discusses the latest version of Italy’s transfer pricing country profile, prepared by Italian Central Revenue, published on the OECD webpage a few days ago, which reflects the agency’s latest views on transfer pricing enforcement . . .

Americas

OECD releases transfer pricing country profiles for Chile, Finland, Italy; updates Colombia, Israel profiles

June 18, 2019

The OECD today released new transfer pricing country profiles for . . .

Europe

Italy amends patent box regime, adopts other tax reforms

May 9, 2019

Davide Anghileri of the University of Lausanne discusses a new package of Italian tax measures which include amendments to Italy’s patent box regime and an asset basis step-up on certain mergers, division, or contributions . . .

Europe

Italy issues draft tax regulations on arm’s length standard, corresponding adjustments

February 22, 2018

Italy’s Ministry of Economy and Finance on February 21 released for public consultation draft regulations designed to align Italy’s transfer pricing rules with the outcome of Actions 8–10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, writes Davide Anghileri, University of Lausanne . . .

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Italy clarifies patent box, R&D tax credit, business assets credit

March 19, 2017

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. . . .

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” 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