Friday, 30 January 2015

New Italian laws include numerous changes relevant to Multinationals

The Italian Budget Law for 2015, effective January 1, 2015, introduces several tax law changes relevant to multinational companies.  In addition, recently enacted legislation, while still subject to Italian parliament approval, favorably changes the Italian patent box regime.
The most important changes from a cross-border perspective include:

  • A new patent box regime that partially exempts income derived from qualifying intangible assets from the corporate income tax.
  • Amended criteria to identify tax-haven jurisdictions in order to apply the anti-tax-haven and controlled foreign company (CFC) rules. 
  • Renewed option (with amendments) to step-up the outside tax basis of Italian shares held by either Italian individuals or non-Italian resident persons.
Source & more info: PwC