Thursday, 7 May 2015

Italian international tax legislation includes major changes to APA rollbacks, taxation of branches and transactions with tax havens

A draft legislative decree was approved by the Italian Government on 21 April 2015 which includes a large number of tax changes, many of which are particularly relevant for companies with international operations. The draft decree is currently under review in the Italian Parliament, and is therefore still potentially subject to modification. The full range of international tax issues covered includes Controlled Foreign Companies rules, transfer of residence, interest deduction rules among others, but for transfer pricing practitioners the main points of interest relate to Advance Pricing Agreements (APAs), deductibility of costs charged by tax haven entities and taxation of permanent establishments.
Source & more info: PwC