Italy

Europe

Italy finalizes tax incentives

August 27, 2014

The Italian Parliament, on August 11, converted a series of tax incentives into law without modification, writes EY in an August 25 report. Included are increased notional interest deduction benefits, a tax credit for new plants and equipment, and an expanded withholding tax exemption for interest and substitute tax for loans. For discussion, see EY.

Europe

Italy enhances its newly enacted patent box regime

January 27, 2015

The Italian government on January 24 passed a law that significantly expands its new patent box regime, allowing additional categories of intellectual property and outsourced activities to qualify, and dispensing with the requirement to obtain a ruling to determine income attributed to IP in many cases, writes EY in a January 27 tax alert. See, EY.

Asia-Pacific

India seeks treaty revisions to make bilateral APAs possible with Germany, France, Singapore, Italy and South Korea

August 27, 2014

India is attempting to renegotiate tax treaties with Germany, France, Singapore, Italy, and South Korea to add corresponding adjustment provisions so that India can sign bilateral advance pricing agreements (APAs) involving these nations, writes Vrishti Beniwal in an August 26 Business Standard article, quoting unnamed Finance Ministry officials. See, Business Standard

Europe

Isle of Man dropped from Italy’s tax blacklist

April 17, 2015

The Isle of Man was dropped from Italy’s tax blacklist regarding deductibility of costs as of April 1, the Isle of Man government announced on April 17. The change was made on account of a new Italian law which provides that jurisdictions that have exchange of information arrangements . . .

Europe

Italy proposes sweeping cross-border tax reform

April 28, 2015

The Italian goverment, on April 21, released draft legislation which “significantly reshapes the tax rules applicable to cross-border scenarios and redefines the concepts of abuse of law and tax avoidance,” writes EY in an April 27 tax alert. According to EY, the draft would replace Italy’s general antiavoidance rules with a new “abuse of law” provision and would expand types of matters that can be the subject of an advance tax ruling. Also included are proposals to modify the tax treatment of transactions with black list countries, the computation of the interest expense deduction cap, attribution of income to Italian permanent establishments, foreign tax credit and controlled foreign corporation rules, and provisions on consolidation between sister companies. See, EY.

UPDATE (05/07/2015): See, also PWC.

Europe

Italy’s Parliament weighing new patent box regime

December 2, 2014

A bill introducing a patent box regime in Italy consistent with the OECD’s nexus approach was submitted to the Italian Parliament in October, writes PwC in a December 2 article. PwC notes that to be eligible for tax benefits under the bill, most taxpayers would need to enter into an advance pricing agreement with revenue authorities. For a detailed discussion of the new provisions, see PwC. See also, DLA Piper, Società Italiana Brevetti

Federal Government
Americas

G7 leaders agree to arbitration for double tax disputes, say OECD should monitor BEPS implementation

June 8, 2015

G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .

UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .