Green Light on the Mutual Recognition of Rulings for Seizure
/Author: Salvatore Mattia e Caterina Alagna
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Articles
OECD Guidelines on CFC Rules
/Author: Piergiorgio Valente
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International Taxation and Fight Against Tax Base Erosion: What Developments?
/Author: Caterina Alagna
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Transfer Pricing: Critical in the Remuneration of the Intangibles
/Author: Piergiorgio Valente
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Green Light for the Italy-Taiwan Agreement
/Author: Piergiorgio Valente
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Thoughts on Italy’s New Patent Box Regime
/Author: Piergiorgio Valente and Federico Vincenti
Italy’s 2015 stability law introduces a new optional privileged tax regime for income deriving from the use of specific kinds of intangibles. The authors provide insights on Italy’s new regime, the so-called patent box.
Aggressive Tax Planning: Disclosure Rules
/Author: Piergiorgio Valente
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2015 CFE Forum: Fighting the Risk of Double Non-Taxation
/Author: Federico Vincenti
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Italy-Vatican: Agreement on Information Exchange
/Author: Piergiorgio Valente
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Italy Introduces a Voluntary Disclosure Procedure
/Author: Salvatore Mattia
Voluntary disclosure represents an important opportunity for taxpayers to regularize their position with the Italian tax authorities. It is a program that complies with OECD guidelines and aims at future voluntary compliance within the broader picture in which the development of a new tax authority/taxpayer cooperation model is being devised.
Professional Liability and Tax Penalties: Critical Issues
/Author: Piergiorgio Valente, Ivo Caraccioli and Alberto Nastasia
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Companies Tax Risk Management and Professional Liability
/Author: Piergiorgio Valente and Ivo Caraccioli
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Tax Information Exchange: Changes to Black and White Lists
/Author: Piergiorgio Valente
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Italian Supreme Court Rules TP Irregularities Must Be Substantiated with Clear Avoidance Behaviour
/Authors: Piergiorgio Valente, Federico Vincenti
In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent.
The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient grounds for an adjustment.
