6/28/2021 1:10:43 PM Exit tax: holding companies may not qualify for Italian participation exemption on migration By Michele Dimonte The Italian Tax Authority confirmed that the participation exemption does not apply to shareholdings that are transferred abroad as part...
3/9/2021 11:31:45 AM Income tax free securitisation of real estate in Italy By Michele Dimonte Andrea Manzitti 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...
1/5/2021 9:20:47 AM Foreign investment funds are exempt from withholding tax on Italian source dividends and capital gains on equities By Michele Dimonte Andrea Manzitti Starting on 1 January 2021, dividends and capital gains earned by qualifying EU/EEA based investment funds (EU/EEA Funds) are exempt from...
11/16/2020 1:54:04 PM Italian “mixed takeover bids" are not tax neutral By Michele Dimonte In principle, a “takeover bid” means a public purchase offer, whether mandatory or voluntary, made to the holders of securities in a...
10/19/2020 9:17:53 AM Voluntary disclosure of “hidden” PE in Italy: it’s time for rejuvenation By Michele Dimonte Three years after entering into force, the time has come to assess the effectiveness of the voluntary disclosure procedure for hidden...
3/30/2020 12:04:39 PM Italian businesses to be allowed to convert DTAs into tax credits By Michele Dimonte On 16 March, the Cura Italia decree (Law Decree No. 18/2020) was approved – effective as of 17 March – to strengthen the health care...
3/17/2020 12:38:56 PM Staff secondments are subject to VAT By Michele Dimonte According to the ECJ, Articles 2(1)(c) and 24(1) of the Principal VAT Directive preclude national legislation that exempts staff...
12/3/2019 12:00:00 AM Fixed establishment through parent-subsidiary relationship By Michele Dimonte In Case C-547/18, Dong Yang Electronics, the ECJ has been asked to revisit the definition of fixed establishment (FE) for VAT purposes...
11/11/2019 1:46:28 PM Towards a "smart" VAT system? By Slaughter and May We live in a world of burgeoning automation. Transactions are increasingly automated in a range of ways, from direct debit (around since...
11/8/2019 5:07:59 PM Gibraltar companies outside the scope of the Parent-Subsidiary Directive By Tanja Velling Michele Dimonte On 24 October, Advocate General (AG) Hogan opined that a company incorporated, and subject to corporation tax, in Gibraltar cannot avail...
10/30/2019 12:00:00 AM Discriminatory tax treatment of foreign Real Estate Investment Funds (REIFs) By Michele Dimonte Are closed-ended Italian REIFs and open-ended REIFs in a comparable position for Italian indirect tax purposes? The ECJ is set to address...