martes, 10 de mayo de 2016

New Italian tax audit guidelines increase scrutiny of certain transactions related to private equity investments

Italy on March 30, 2016, released Circular letter no. 6/E/2016 (the Circular), which will increase scrutiny of leveraged buyout (LBO) transactions and intermediate non-Italian holding or financing companies. The Circular generally applies to private equity investments in Italy, and applies to past as well as future transactions.

Foreign investors should perform a review of intermediate entities to confirm that the material and economic substance of those entities aligns with the Circular, and that they maintain the ability to defend themselves in case of a dispute. Taxpayers also should evaluate the tax treatment of their fund investor bases and should consider potential ultimate investor tax benefits, such as treaty access and domestic exemptions.

Source & more info: PwC

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