Authors: Piergiorgio Valente and Luigi Vinciguerra

The use of artificial structures or "constructions" and the exploitation of "disharmony" existing between national laws have the effect of exacerbating the loss of tax revenue. The fight against tax evasion and aggressive tax planning schemes requires joint coordinated interventions aimed at facilitating access to information on cash flows and traceability of payments. In order to achieve this, tax systems transparency, the elimination of banking secrecy, and administrative cooperation between States play a key role.
The implementation of the exchange of information, in all its forms (on request, automatic, spontaneous, etc.), represents the most effective response to practices that undermine tax bases and tax revenues.

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Authors: Piergiorgio Valente and Luigi Vinciguerra

Non-resident foreign entities producing corporate income on Italian territory may register as permanent establishments (thus becoming fully subject to taxation in Italy) or may take a series of actions leading to the creation of “hidden” permanent establishments, as they operate within Italian legal entities partially-owned by foreign companies or bodies.
To eliminate this risk, each company should carry out accurate analyses and identify and abide by specific guidelines.

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