Italy Tax News
Dutch dividend withholding tax exemption extended to certain EEA countries
Scope of CFC rules broadened
Requirements for withholding tax exemption for interest and royalties paid to EU associated companies clarified
ECJ finds Finnish dividend withholding tax regime incompatible with EC freedom of establishment
ECJ: Netherlands' non-exemption of dividends paid to certain EEA countries from withholding tax found incompatible with EEA Agreement
Tax treatment of dividends paid to EU and EEA countries clarified
Protocol to treaty between Russia and Italy signed
Protocol to treaty between Cyprus and Italy signed
ECJ: Cobelfret extended to domestic situations and potentially to dividends received from third countries
European Commission refers Germany to ECJ over taxation of outbound dividends
Protocol to treaty between Malta and Italy signed
Italian tax authorities ruling that CFC regime applies when indirect participation, via transparent entity (France) and trusts, in companies resident in black list countries (Isle of Man, Mauritius)
Treaty between Iceland and Italy enters into force
Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies resident in other Member States justifiable restriction on EC freedom of establishment – details
ECJ: Advocate General finds Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details
Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages
OECD released 2008 Model Tax Convention
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment
Treaty between Italy and Iceland ratified
Discussion draft on New Art. 7 of OECD Model – details
OECD Council approves 2008 Model Tax Convention
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
Treaty between Latvia and Italy enters into force
Treaty between Italy and Belgium – Italian tax authority rules on tax qualification of payments under non-competition agreement
Comments on draft contents of 2008 update to Model Tax Convention published
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
Unify Your Processes
Simplify Compliance
Empower Your Team