European Tax

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....

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...

On 16 October 2023 the Italian Government preliminarily approved a legislative decree to implement a reform regarding international...

There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...

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...

One of the consequences of the entry-into-force of the Italian requirement for virtual asset service providers (VASPs) and e-wallet...

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...

Starting on 1 January 2021, dividends and capital gains earned by qualifying EU/EEA based investment funds (EU/EEA Funds) are exempt from...

In principle, a “takeover bid” means a public purchase offer, whether mandatory or voluntary, made to the holders of securities in a...

Three years after entering into force, the time has come to assess the effectiveness of the voluntary disclosure procedure for hidden...