Italy Tax News
CFC rules apply to Italian company with subsidiary and branch in black listed country, even if actual business activity carried on
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
Treaty between Italy and Latvia – ratified by Italy and details
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Dividends and capital gains: new percentage of exemption
Treaty between Italy and Tunisia – Italian tax authorities rule on whether domestic tax credit is available on portion of prélèvement fiscal global
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive
Merger of UK companies with Italian PEs: tax consequences
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
OECD released discussion draft on transactional profit methods
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Deemed Italian tax residence for Dutch holding company
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
Draft Budget for 2008 – highlights
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
Treaty between Ireland and Italy – Irish High Court rules treaty covers CGT
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
CFC regime applies if company resident in black list country regardless of effective tax rate
Deductibility of costs incurred for acquisition of financial lease contract
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Badwill in a transfer of a going concern transaction
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