Italy Tax News
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Transfer pricing: burden of proof on tax administration
Budget for 2007 – corporate taxation: highlights
Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
Taxation of Australian residents performing independent services for Italian entity explained
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
Thin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed
CFC rules: Council of State (Consiglio di Stato) approved implementing rules for "related entities"
Treaty between Peru and Italy – negotiations
Ruling on application of EC Parent-Subsidiary Directive to trust companies
Treaty negotiations between Saudi Arabia and Italy
Protocol between India and Italy – details
Treaty between Ireland and Italy – Irish CGT not covered
Corporate immigration – Italian resident status commences on date of deregistration from Spanish register of companies and transfer of effective management to Italy
Protocol between India and Italy signed
Guideline on implementing EU Interest and Royalties Directive published
Draft Budget Bill for 2006 Participation exemption regime
On 3 November 2005 the Indian Union Cabinet gave its approval for the signing of a protocol amending the India-Italy income tax treaty of 19 February 1993. Further details of the protocol will be reported subsequently.
Draft Budget Bill for 2006 capital losses
Decree-Law modifying participation exemption regime approved by government
In September 2005, the Revenue Commissioners announced the withdrawal, pending the receipt of legal advice on the subject, of their previous view that Irish capital gains tax is a tax
Italy implements EU Interest and Royalties Directive
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