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Dividends received by Italian financial intermediaries (including banks) from their subsidiaries are subject to Italy’s regional tax on...
The Italian tax authority (ITA) ruling (13/2025) concerned an Italian company that provided IT services to a company resident in Egypt....
With support from the IMF, since December 2022 Egypt has been engaged in a policy reform to address economic imbalances. During the...
Does an Italian investment manager create a permanent establishment for a foreign investment vehicle? Not necessarily – especially now...
Italy has introduced legislation concerning the set of documentation to be prepared for hybrid mismatch cases. The new rules include a...
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On 16 October 2023 the Italian Government preliminarily approved a legislative decree to implement a reform regarding international...
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In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
The Italian tax authorities continue to challenge interposed conduit entities using the beneficial ownership test to deny withholding tax...
Under the current legislation, Italy taxes non-resident entities only on capital gains derived from a direct sale of Italian immovable...
A recent Italian Supreme Court decision could have far-reaching consequences for Italian tax provisions on cross-border dividend...
Italian Supreme Court Decision No. 3380 of 3 February deals with the interpretation of the beneficial owner (BO) requirement under the...
The Italian Tax Authority confirmed that the participation exemption does not apply to shareholdings that are transferred abroad as part...
In a recent ruling (No. 132 of 3 March 2021) the Revenue Agency has confirmed that SPVs used to secure proceeds from the direct ownership...