On 21 April 2015, the Italian government approved draft tax reform legislation, which will be sent to parliament. The legislation includes a number measures in regard to permanent establishments (PE), foreign tax credits, deduction limits, tax rulings, and others. Key measures are summarized as follows.
Italian PEs of Foreign Entities
The legislation includes an approach to the attribution of income to PEs in Italy in line with the Authorized OECD Approach. Italian PEs and foreign headquar…