Articles
- Articles (415)
Italian Revenue Agency publishes guidelines for adoption of a tax control framework
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the fra...
Cross-border workers Italy-Switzerland: the rules on teleworking will change from 2024
The first DAC 7 communication is approaching: managers of online platforms subject to the communicat...
La Repubblica: When everything changes, the key is to anticipate.
Today in La Repubblica, Piergiorgio Valente discusses the evolution of the workplace, shaped by the ...
Italy: Transfer pricing legislation not applicable to domestic intercompany transactions
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyze a recen...
Italy: The selection of the ‘best’ transfer pricing method
Federico Vincenti and Carola Valente analyzes a recent ruling by the Italian Supreme Court, publishe...
Italian Supreme Court accepts selection of loss-making comparables in TP
14 Agosto, 2024…...
Three Nominations at the ITR Awards for 2024!
Crowe Valente/Valente Associati GEB Partners Awards Nomination
...
Guide to Italy’s cooperative compliance regime for managing tax risks
A new article on International Tax Review is out that you won’t want to miss: check out the compre...
National minimum tax: how it is calculated and to whom it applies
The national minimum tax aims to ensure that multinational companies pay a minimum tax rate on their...
Italian Supreme Court decisionconfirms stance on intercompany services
A new article on International Tax Review is out that you won’t want to miss: the Italian Supreme ...
Italian Supreme Court issues decision on interest-free intercompany loan
A new article on International Tax Review is out that you won’t want to miss: The Italian Supreme ...
Italy’s investment management exemption: new TP regulations for asset managers’ remuneration
A new article from International Tax Review is online: Italy has introduced significant updates to t...
Shortened deadline for drafting TP documentation in Italy
Don’t miss the new article on International Tax Review: Italy has shortened the deadline for draft...
Italy continues reforms by revising its international tax principles
A recent legislative decree sets out highly significant updates to Italy’s international taxation ...
Guide to transfer pricing and financial transactions, with an Italian nuance
Carola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD ...
How to manage ESG, value chains, and transfer pricing considerations
Carola Valente of Crowe Valente/Valente Associati GEB Partners explains why ESG goals and requiremen...
Artificial Intelligence: Taxation and Taxpayers in the Metaverse
Artificial Intelligence (AI) is transforming the tax system, improving data analysis, combating frau...
Italian Revenue Agency ruling addresses permanent establishments, VAT and TP
Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners report on a...
Italy: Unilateral Tax Settlement And Mutual Agreement Procedures
Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners explore the...
The Public Country-By-Country Reporting Directive Arrives In Italy
Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners explain the...
The Italian Supreme Court rules on preferring the “internal CUP method” over the “external CUP method”
Don’t miss the new article on International Tax Review: The Italian Supreme Court has issued a key...
The Italian Supreme Court Rules On Preferring The “Internal CUP Method” Over The “External CUP Method”
Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners analyse the...
Intangibles and DEMPE analysis: on tax authorities’ radars worldwide
Federico Vincenti and Alessandro Valente discuss the importance of DEMPE analysis and the subsequent...
Black list costs, crypto-assets and permanent establishment: new rules to encourage investments (and guarantee taxation)
The 2023 Budget Law introduces tax innovations to attract investments and guarantee taxation:Costs f...
Impact Of Italian Guidelines On TP Audits And APAs
In recent years, this firm has assisted in an increasing number of tax audits related to transfer pr...
Italian Revenue Agency Issues Clarifications On Arm’s-Length Range
Federico Vincenti and Alessandro Valente of Valente Associati GEB Partners/Crowe Valente explain how...
Clarification on TP Documentation in Italy Starts Moving Forward
On September 20 2021, the Italian Revenue Agency (IRA) published the draft circular letter (the Circ...
Assessing the Tax Treatment of Employees Working in Italy during the Pandemic
In a response to the disruption caused by the COVID-19 pandemic, governments have enacted unpreceden...
Italian Supreme Court Rules on uneconomical inter-company Transactions
In early 2021, two decisions of the Italian Supreme Court dealt with the issue of certain inter-comp...
The Importance of Mutual Agreement Procedures in International Tax Disputes
The mutual agreement procedure (MAP) is an instrument for the resolution of international tax disput...
A Review of Advance Tax Agreements in Italy
Advance tax agreements are binding agreements between taxpayers and the Italian Revenue Agency aimed...
Rethinking the Top-Line and Realignment of the Bottom-Line in a Post-Covid Landscape
As many countries around the world are facing the second wave of the Covid-19 crisis, and given the ...
Assessing Inter-Company Transactions and Accounting Implications during Economic Uncertainty
Inter-company financial transactions
During periods of crisis, the financial sector may experience s...
Performing a Comparability Analysis during an Economic Downturn
Since December 2019, countries have witnessed the widespread impact of COVID-19 on economic activity...
TP Liabilities on Criminal Tax in Italy: Assessing, Adopting and Avoiding
During the course of tax audits, Italian tax authorities often challenge the value of the goods or s...
Taxing the Digital Economy: a Realistic Goal for 2020?
An ambitious project.
New year. New resolutions.
From an international taxation perspective, the res...
Italy Issues Changes to the Operation of Country-by-Country Reporting
The Ministry of Economy and Finance has produced some amendments regarding the use of the data and i...
Strategic Partnership with European Parliament
In October 2019, CFE Tax Advisers Europe celebrated its 60th Anniversary under the high patronage of...
Advance Pricing Arrangements: Optimal Tool – Optimal Framework?
Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation ...
Global Tax Advisers’ Platform
GTAP: 2019 Convention
On 3 October 2019, the Global Tax Advisers’ Platform (GTAP) members convened...
Taxation in the Future – A New EU: Vision and Impact
The Change of Scenery
On 1 December 2019, the von der Leyen Commission took over for the coming 5 y...
Evaluating TP Policies in Loss-Making Companies
During tax audits, tax authorities frequently focus on companies within multinational groups that bo...
Italy Amends its Patent Box Regulation
The patent box regime was introduced in Italy with the Legge di Stabilità 2015 and has been subject...
Quattro Priorità per Equità ed Efficienza dei Sistemi Fiscali Internazionali
La Global Tax Advisers Platform (“GTAP”), piattaforma internazionale che rappresenta oltre 600.0...
Let’s Meet in Matera and Celebrate IAFEI’s 50th Anniversary
In the year in which IAFEI celebrates its 50th anniversary, the 49th Congress of IAFEI will take pla...
Mobility Monday’s – Transfer Pricing, How Costs of Employees is Born and Cross Charged
Tax issues and global mobility go hand in hand. There can be tax matters for the employee and for th...
Blockchain Technology: Driving Towards the Next Industrial Revolution?
New technologies have provoked a new revolution in human history: the so-called “digital revolutio...
The Impact of TP Policies on Managing a Company in Crisis
The Italian government, with Legislative Decree No. 14 on January 12 2019, approved the new Code of ...
Italy Clarifies Key Transfer Pricing Tenants
Italy’s tax authority clarified a number of transfer pricing regulations at the nation’s annual ...
Cyber-Diplomacy and Digital: Some Legal and Economic Aspects
For thousands of years the human species was constrained to limit its activities and creativity in t...
Italy Refines Transfer Pricing Methodology
On May 14 2018, the Italian Ministry of Economy and Finance issued a decree providing guidelines for...
The Italian Web Tax from a National and International Perspective
Published in: IBFD Europe an Taxation – May 2018
To ensure taxation of digital business prof...
Digital Revolution. Tax Revolution?
What seemed like science fiction a few years ago is now science fact. This is referred to as the “...
Italy Holds Public Consultation on New Transfer Pricing Rules
Published on: TP Week
On April 24 2017, the Italian provision on transfer pricing, article 110 parag...
EU Black List, a New Perspective on Tax Havens
Published on: IAFEI Quarterly 39th Issue, January 2018
The European Union recently took one more ste...
Spirit of Tax Law and Tax (Non-)Compliance: Reflections on Form and Substance
Published in: IBFD European Taxation January 2018
In complying with their tax duties, multinationals...
Italy’s Tax Police Publishes Manual against Tax Evasion and Fraud
Published in: TP Week
On December 4 2017, the Italian Financial Guard (Tax Police), updated its prac...
A European Taxpayers’ Code
Published in: Journal – Intertax 45-12
The European Commission published ‘Guidelines for a ...
Italy Turns Up the Heat on EU with Digital Sales Tax
Published in: TPWeek
Italy is hoping its proposed digital sales tax will send a message to the EU an...
CbCR Obligations for Italian Entity Members of US Groups
Published in: TPWeek
An agreement for the automatic exchange of country-by-country reports (CbCR) be...
And the Blame Goes to… EU Tax Intermediaries
Published in: IAFEI 37th issue
In June 2017, the European Commission released the fiercely debated p...
Taxless Corporate Income: Balance against White Income, Grey Rules and Black Holes
Published in: European Taxation – IBFD
The potential of globalization and digitization is clea...
Capturing Dematerialized Money through Anti-Money Laundering Provisions
Published in: Kluwer International Tax Blog
The Committee on Economic and Monetary Affairs and the C...
Lawyer Monthly – Women In Law Awards Edition 2017
The Lawyer Monthly Women in Law Awards celebrate and highlight the achievements of women in the lega...
Transfer Pricing Audits: Suitability of Transfer Pricing Documentation
Pubblicato su: Intertax – Issue 45.6&7
Article 26 of Legislative Decree No. 78/2010 introd...
Cooperative Compliance: The Italian Framework
Pubblicato su: TPWeek
On May 26 2017 the Italian regime on cooperative compliance was further clarif...
BEPS Action 15: Release of Multilateral Instrument
Published in: Journal – Intertax (Issue 45.3)
The release of the Multilateral Instrument con...
Changing the Italian Tax System
Italy has embarked upon the challenging task of redesigning its tax system. The Act of late November...
Suitable TP Documents Could Prevent Penalties in Italy: But What Is “Suitable”?
Published in: TP Week
Multinationals with activities in Italy can get rid of penalties for tax avoid...
Suitable TP Documents Could Prevent Penalties in Italy: But What Is “Suitable”?
Pubblicato su: TP Week
Multinationals with activities in Italy can get rid of penalties for tax avoi...
Italy’s Anti-BEPS Struggles
Published in: TP Week
The OECD-recommended measures to counter tax evasion have been integrated in t...
Transfer Pricing and Business Restructuring
L’OCSE in data 4 luglio 2016 ha pubblicato un documento for public review “Conforming Amendments...
Residence of Individuals Under Italian, International and EU Laws
Under Italian legislation, the tax residence of individuals is regulated by Article 2 of the TUIR (i...
Changes to Advance Agreements in Italy
Pubblicato su: Tax Notes International (Volume 83, Number 12 – September 19, 2016)
Regulation...
Italian Revenue Office Clarifications on CFC Rules
Published in: TP Week, Sep. 21, 2016
After the Italian Revenue Office issued new guidance on CFC reg...
Italian Perspective on BEPS and Focus on Implementation of Action 13 of the BEPS Action Plan
Published in: Intertax Magazine Volume 44 Issue 8 & 9
Italy has been paying special attention, t...
ANDAF Contribution to the EU Consultation on the CCCTB
Published: IAFEI Quarterly 33rd Issue
On January 8, 2016, ANDAF (Italian CFO Association) submitted ...
Double Taxation Dispute Resolution Mechanism and Answer by IAFEI International Tax Committee
Published: IAFEI Quarterly 33rd Issue
On April 11, the IAFEI submitted its contribution to the EU Co...
News Analysis: The Italy-Vatican Treaty Relationship
Published in: Tax analysts Worldwide Tax Daily
Italy ratified the pending tax information exchange a...
The EU Anti-Tax-Avoidance Directive’s Effect on Italy
Pubblicato su: Tax Notes Int’l, Aug 8 2017
The anti-tax-avoidance directive (COM(2016)26) prop...
Age of Fairness? Tax and Social Responsibility Dimensions
Published in: Kluwer International Tax Blog
Corporate Social Responsibility (“CSR”) has become ...
A Experiência Da Multidisciplinaridade Em Itália
Published in “Advocatus Magazine” (June 2016 Edition)
É portuguesa, nascida e licenciada no Por...
Transfer Pricing Audits: Approach by Italian Tax Authorities
Within Europe, policies have been developed to enable the free circulation of people, goods and ser...
SELF-EMPLOYMENT WITHIN AN INTERNATIONAL FRAMEWORK – Tax And Employment Regimes
Authors: Piergiorgio Valente, Danilo Massimo Cardone, Raffaele Rizzardi and Paola Salazar
To purchas...
Transfer Pricing: An Overview of the Italian Supreme Court’s Recent Rulings
Published in: Intertax Magazine Volume 44 Issue 6 & 7
Rulings on transfer pricing matters issued...
Transfer Pricing: ‘Broad-Based’ Control Concept Pursuant to Italian Courts
Published in: TP Week, May 25, 2016
Article 110, paragraph 7 of the TUIR (i.e., Italian Income Tax C...
Patent Box in Italy: Guidelines Issued by the Italian Revenue Office
Published in: TP Week
The 2015 Stability Law introduced in Italy a new patent box regime for incomes...
Overview on the BEPS Final Package
Published in: IAFEI Quarterly 32nd Issue, April 2016
Some are of the view that we are witnessing a ...
Italian Tax Authorities Clarify APA Procedure
Published in: TP Week, March 29, 2016
On March 21 2016, the director of the Italian Revenue Office (...
Transfer Pricing and Patent Box: New OECD Rules
I nuovi obblighi di documentazione del transfer pricing e i regimi agevolati per le imprese che inve...
Further Exchange of Information in Order to Counteract Profit Shifting
La cooperazione fra i diversi Paesi finalizzata allo scambio automatico di informazioni in materia f...
Country-by-Country Reporting Under Italian Law
Published on: TP Week
Data: 15.02.2016
In line with international developments, the Italian Governme...
How the Apple Settlement reflects Italian Focus on TP (including Valente Associati GEB Partners’ Contribution to the Feature)
Published in: TP Week
Date: 12.01.2016
“Never before has the international tax arena assumed such ...
A 2016 “Look-Ahead” – BEPS Implementation to Dominate International Tax Landscape in 2016 (including Valente Associati GEB Partners’ contribution to the feature)
Published in: International Tax Review’s December/January double issue
With the final deadlines fo...
Importance of the Multilateral Instrument on the Implementation of BEPS Measures
Autore: Piergiorgio Valente
The article was published in the “Rivista Il fisco” (il fisco 47-48/...
Critical Issues and Future Prospects to Counter Base Erosion through Profit Shifting (BEPS): Status Report
International transparency and cooperation within the tax arena are two fundamental principles that ...
Ivo Caraccioli and Piergiorgio Valente On International Taxation
Download (In italian)…...
Recent Italian Transfer Pricing Decisions
Published in the November 2, 2015 issue of Tax Notes International
Download…...
Premio Internazionale Le Fonti – CEO Summit 2015 & Awards
Published in: Harvard Business Review
Grande Successo per la V Edizione del Premio Internazionale Le...
Piergiorgio Valente On Italy-Vatican Agreement
Dopo la sottoscrizione degli accordi con Svizzera, Liechtenstein e Principato di Monaco, l’Italia...
Piergiorgio Valente on Italy-Switzerland Agreement
Download (in Italian)…...
Achieving a Fairer and More Efficient Corporate Tax System within the EU
On June 17, 2015, the EU Commission released a new Action Plan focusing on ensuring a Fair and Effic...
Competition and Base Erosion and Profit Shifting (BEPS)
Competition is rather harsh and has increased and countries are suffering from a significant decreas...
Luigi Pintaldi on Infomation Exchange
Download (in italian)…...
BEPS – What Are We Headed For?
With the BEPS (Base Erosion and Profit Shifting) project nearing its completion, it is time for the ...
Base Erosion and Permanent Establishment
Author: Piergiorgio Valente
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Italian Proposals Endorsing Internationalization of Financial Enterprises
Authors: Caterina Alagna, Federico Vincenti
Law No. 23, issued March 11, 2014, tasked the Italian go...
Ratification of Cayman Islands-Italy Agreement Published in the Official Gazzette
Autore: Piergiorgio Valente
Download (Italian)…...
Directive on Parent-Subsidiary Companies: Changes Ahead
Author: Piergiorgio Valente
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Ratification of Italy-Honk Hong Agreement Published in the Official Gazzette
Author: Piergiorgio Valente
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European Action Plan on Taxation to Improve Fairness and Efficiency
Author: Piergiorgio Valente
Download (Italian)…...
Signed the Switzerland – EU Agreement: Banking Secrecy is History
Author: Piergiorgio Valente
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Disclosure Duties and New Tax Authorities – Taxpayer Relations
Author: Caterina Alagna
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The Taxpayer Statute: Past, Present and Future
Author: Marco Pontani
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Guidelines for the Countering of Tax Evasion and Avoidance
Author: Piergiorgio Valente and Danilo Massimo Cardone
Download (Italian)…...
Green Light on the Mutual Recognition of Rulings for Seizure
Author: Salvatore Mattia e Caterina Alagna
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OECD Guidelines on CFC Rules
Author: Piergiorgio Valente
Download (Italian)…...
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 op...
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 r...
Professional Liability and Tax Penalties: Critical Issues
Author: Piergiorgio Valente, Ivo Caraccioli and Alberto Nastasia
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Financial Statements of Italian Companies: Topics Under Discussion at the Forum Bilancio
Author: Caterina Alagna
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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 rejecte...
Taxpayer and Tax Agency: Rights and Obligations Under the Model Taxpayer Charter
Author: Piergiorgio Valente
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Italy and Monaco Sign TIEA
Author: Piergiorgio Valente
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OECD, Contrast to Base Erosion and Mutual Agreement Procedures
Author: Piergiorgio Valente
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Base Erosion: BEPS Actions Discussed at G20
Author: Piergiorgio Valente
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Switzerland and Italy Sign DTA
Author: Piergiorgio Valente
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The DTA Protocol Between Italy and Luxembourg
Author: Piergiorgio Valente
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Italy’s Patent Box Regime Should Escape Criticism Because of Alignment with OECD Nexus Approach
Author: Piergiorgio Valente, Davide Bergami, and Sophie Harding
Italy has introduced a patent box re...
Information Exchange: White List and Black List Modifications
Author: Piergiorgio Valente
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Transfer Pricing: Relevance and Criticality of Functional Analysis
Author: Piergiorgio Valente
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Forthcoming Italy – Principality of Monaco Taxation Agreement
Author: Piergiorgio Valente
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Italy and Liechtenstein Sign TIEA
Author: Piergiorgio Valente
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Taxpayer-Tax Authorities: Duties and Rights According to the Model Taxpayer Charter
Author: Piergiorgio Valente
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Preparation of Financial Statements, New Responsibilities and Obligations
Author: Caterina Alagna
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Transfer Pricing: Payment of Low Added Value Services
Author: Piergiorgio Valente
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Tax Base Erosion: BEPS Measures Discussed at the G20
Author: Piergiorgio Valente
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Italian Companies’ Financial Statements: What Was Reviewed at the Forum Bilancio
Author: Caterina Alagna
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Italy-Luxembourg: into force the Additional Protocol
Author: Piergiorgio Valente
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OECD Contrast to the Tax Base Erosion and Mutual Agreement Procedures
Author: Piergiorgio Valente
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The Tax Shield Cannot Become an Alibi
Author: Ivo Caraccioli
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The Transfer Pricing Implications of the Italian Regional Tax on Productive Activities
Author: Piergiorgio Valente
The provincial tax court of Reggio Emilia has issued ruling No 510/03/14...
Council agreement on the revision of the Directive on Administrative Cooperation
Author: Piergiorgio Valente
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Tax Evasion and abuse of Law according to the National and International Framework
Author: Piergiorgio Valente
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Delegated Tax Law: Some Insights and Open Issues
Author: Caterina Alagna
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Agreement Switzerland – EU to abolish contested corporation tax regimes
Author: Piergiorgio Valente
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The Italian Approach to Intercompany Loans
Author: Piergiorgio Valente
The Italian tax authorities have been intensifying their focus on transf...
OECD Recommendations on Digital Economy, Treaty Abuse, and Transfer Pricing
Author: Piergiorgio Valente
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Tax Base Erosion and Profit Shifting in Developing Countries
Author: Piergiorgio Valente
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Italian Taxation of Corporate Residence Transfers
Author: Piergiorgio Valente
The decision to transfer an enterprise’s corporate seat abroad general...
Italy: Transfer Pricing Aspects of Restructuring
Author: Piergiorgio Valente
Corporate restructuring operations and/or functional redefinition involv...
Counteracting Tax Evasion: the priorities of the semester of the Italian Presidency of the EU Council
Author: Piergiorgio Valente
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Transfer Pricing: New Guidelines Issued by the EU Commission
Author: Piergiorgio Valente
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Base Erosion and Profit Shifting and Leverage: Applications to Permanent Establishments
Author: Piergiorgio Valente
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Tax Rulings and State Aid: the EU Commission Investigations
Author: Piergiorgio Valente
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Italy-Luxembourg: Exchange of Information Without Limits
Author: Piergiorgio Valente
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Countering BEPS Through Transfer Pricing Documentation
Published in: European Taxation June 2014
In today’ s globalized economy, transfer pricing plays ...
Proposals for a Fairer Tax Policy, Justice Reform, and a European Taxpayer Statute
Author: Ivo Caraccioli, Fabio Ghiselli, Salvatore Mattia, Raffaele Rizzardi, and Piergiorgio Valente...
Italy-San Marino: Ratification of Economic Cooperation Agreement
Author: Salvatore Mattia and Caterina Alagna
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Italian Supreme Court Ruling Maintains Arm’s-length Principle Must Apply to Related Companies Within Italy
Author: Piergiorgio Valente
The Italian Supreme Court ruled, on April 16, that all transactions carr...
Digital Economy: Dedicated Tax Legilslation Vetoed
Author: Piergiorgio Valente
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Change of Climate in Taxation: Are You Prepared for Extended Responsibilities?
Author: Filipa Correia and Rudolf Reibel
Against the background of recent international and EU actio...
Proposal for a General "Tax Compliance" Manifesto and the Relationship Between the State and the Citizen-Taxpayer
Author: Ivo Caraccioli, Fabio Ghiselli, Salvatore Mattia, Raffaele Rizzardi and Piergiorgio Valente
...
Tax Residence and Permanent Establishment: New Developments
Author: Piergiorgio Valente and Salvatore Mattia
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Italy – Hong Kong Treaty: Ratification Bill Approved
Author: Piergiorgio Valente
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Negotiating Italy’s Arbitration Convention
Author: Piergiorgio Valente
Arbitration Convention No. EEC/90/436, approved on July 23 1990, sets fo...
Tax Governance and Strengthened Cooperation with Tax Authorities
Author: Agostino Nuzzolo and Piergiorgio Valente
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Tax Assessment Activities According to the Model Taxpayer Charter
Author: Piergiorgio Valente
The envisaged purpose of the Model Taxpayer Charter is for such Charter ...
Italy-US FATCA Agreement: Legislative Decree Moves Forward
Author: Piergiorgio Valente
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Taxation of Seconded Personnel
Author: Salvatore Mattia and Federico Vincenti
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The New OECD Standard for Automatic Exchange of Financial Account Information
Author: Piergiorgio Valente
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Contrasting International Tax Avoidance in the EU
Author: Caterina Alagna and Stefano Lavore
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Exchange of Information: Recent International Trends
Author: Piergiorgio Valente
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Digital Economy: the OECD Public Discussion Draft
Author: Piergiorgio Valente
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Savings Directive: Strengthening Exchange of Information Rules
Author: Piergiorgio Valente
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OECD Publishes Discussion Drafts on Hybrid Mismatch Arrangements
Author: Piergiorgio Valente
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Treaty Abuse: OECD Public Discussion Draft
Author: Piergiorgio Valente
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San Marino Removed from Tax Black List
Author: Piergiorgio Valente and Salvatore Mattia
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Tax Governance and Financial Statements: Tax Transparency, New Duties and Responsibilities
Author: Caterina Alagna
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National and International Accounting Principles: Evolving Financial Statements
Author: Caterina Alagna
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The Review of OECD Regulation on Transfer Pricing Documentation
Author: Piergiorgio Valente
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Secondment of Workers Abroad
Author: Salvatore Mattia and Federico Vincenti
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The OECD Presents the “Standard for Automatic Exchange of Financial Account Information”
Authors: Piergiorgio Valente, Caterina Alagna
The “Standard for Automatic Exchange of Financial A...
Art. 25 of the OECD Model Tax Convention: the Mutual Agreement Procedure
Author: Piergiorgio Valente
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EU Joint Transfer Pricing Forum: the Report on Compensating Adjustments
Author: Piergiorgio Valente
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Transfer Pricing Documentation and Country-by-Country Reporting: the OECD Discussion Draft
Author: Piergiorgio Valente
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Italy-Taiwan: the Decree Law for the Regulation of Tax Relations Among the Two States Has Been Approved
Author: Piergiorgio Valente and Federico Vincenti
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BEPS and Financial Transactions: Tax Base Erosion and International Avoidance
Author: Piergiorgio Valente
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Business Trips and Mileage Reimbursements: Tax, Labor, and Criminal Law Aspects
Author: Ivo Caraccioli and Salvatore Mattia
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Italy-USA: Enhanced Cooperation Against Tax Evasion
Author: Piergiorgio Valente
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IRAP and Application of TP Regulation: Clarifications
Author: Piergiorgio Valente, Raffaele Rizzardi and Salvatore Mattia
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Update on Italian Regional Tax on Productive Activities Brings Clarity
Author: Piergiorgio Valente
Before 2014, IRAP (the Italian Regional Tax on Productive Activities) re...
Italian Supreme Court Reinforces Arm’s-length Principle
Author: Piergiorgio Valente
Piergiorgio Valente, managing partner of Valente Associati GEB Partners,...
Changes to the Italy-Luxemburg Treaty: Bill Approved
Author: Piergiorgio Valente
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How to Avoid Italian Criminal Charges in Transfer Pricing Litigation
Author: Piergiorgio Valente
Practitioners should pay attention to the observations outlined below to...
Permanent Establishment of Banks: Allocation of Profits and Endowment Fund according to Italian Practice and Case Law
Author: Piergiorgio Valente
The assignment of profits and the formation of the so-called “endowmen...
Italy-Gibraltar: Agreement on Exchange of Information on Tax Matters
Author: Piergiorgio Valente
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Internal Transfer Pricing
Author: Piergiorgio Valente, Ivo Caraccioli and Salvatore Mattia
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Double Taxation: the Tax Credit Mechanism
Author: Salvatore Mattia and Caterina Alagna
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Tax Advisers Face New Liabilities: Update on International Debates
Author: Piergiorgio Valente
The sixth Conference of the CFE’s (Confédération Fiscale Européenne...
Tax Advisers’ Liability Under Italian Criminal Tax System
Author: Ivo Caraccioli
Tax Advisers may effectively run the risk of being incriminated for tax crime...
Italian Case Law on the Usability of “Falciani’s List”
Author: Piergiorgio Valente, Ivo Caraccioli and Salvatore Mattia
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Base Erosion and Automatic Exchange of Information: the OECD Report at Saint Petersburg G20 Meeting
Author: Piergiorgio Valente
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International Tax Evasion and Tax Governance Models
Author: Piergiorgio Valente
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Tax Governance, Aggressive Tax Planning and Base Erosion
Author: Piergiorgio Valente
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The Fight Against Tax Fraud and Tax Evasion: Developments at EU Level
Author: Ivo Caraccioli, Salvatore Mattia and Caterina Alagna
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Base Erosion and Profit Shifting. The OECD Action Plan
Author: Piergiorgio Valente
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Tax Good Governance and Aggressive Tax Planning: the Institution of the EU Platform
Author: Piergiorgio Valente
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Change of Climate in Taxation – Extended Responsibilities for Tax Advisers? – CFE Professional Affairs Conference of 22 November 2013 in Milan
Author: Piergiorgio Valente
Recent initiatives against “harmful tax practices” are moving existi...
Transfer Pricing Documentation: the OECD White Paper
Author: Piergiorgio Valente
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Italy’s Exchange of Information Procedures
Author: Piergiorgio Valente
The 2013 Law of European Delegation gives the Italian government the pow...
Fight Against Money Laundering: Developments in the Vatican Legal System
Author: Piergiorgio Valente
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International Debate on the Erosion of the Taxable Base
Author: Piergiorgio Valente
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The Convention between Italy and San Marino Entered into Force
Author: Piergiorgio Valente
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Accounting and Taxation: National Regulations and International Developments
Author: Caterina Alagna and Federico Vincenti
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Taxation and Tax Contribution Capacity Index
Author: Salvatore Mattia and Federico Vincenti
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International Actions for Contrasting the Erosion of the Taxable Base: Which Perspectives?
Author: Piergiorgio Valente
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The Supreme Court Decision No. 22010/2013: Arm’s Length and Intercompany Transactions
Author: Piergiorgio Valente and Raffaele Rizzardi
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Model Taxpayer Charter – Charter of Rights and Duties of Taxpayers, Cooperation with Tax Administrations between Tax Governance and Tax Compliance
Author: Piergiorgio Valente, Ian Hayes and Dick Barmentlo
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Country-by-country Reporting: Recent Developments at EU Level and Stakeholders’ Position
Author: Piergiorgio Valente
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A Global Model for the Exchange of Information
Author: Piergiorgio Valente
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Italy’s Participation to EU Policies: the Legislative Decree of September 20, 2013
Author: Piergiorgio Valente
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The Agreement for the Exchange of Information Between Italy and the Isle of Man
Author: Piergiorgio Valente
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The Fight against Tax Evasion: a Key Element for the Global Economic Recovery
Author: Piergiorgio Valente
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Tax Avoidance Issues Arising from Hybrid Mismatch Arrangements
Author: Piergiorgio Valente
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Permanent Establishment and Jurisdiction to Tax: Debates in Italy
Author: Piergiorgio Valente
In the last few months, major European governments have struggled with t...
Transfer Pricing: Risks Assessment According to the OECD
Author: Piergiorgio Valente
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Multilateral Convention on Mutual Administrative Assistance: Adhesion Trends
Author: Piergiorgio Valente
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INTRASTAT Models for Received Services Have Been Repealed
Author: Marco Peirolo
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Italy’s Transfer Pricing Regime and IRAP
Authors: Piergiorgio Valente, Salvatore Mattia
The IRAP is Italy’s regional business tax. Establis...
Intercompany Financial Transactions: Valuation Aspects, Benchmarking Analysis and Critical Issues in Transfer Pricing
Author: Antonella Della Rovere and Salvatore Mattia
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Aggressive Tax Planning: Tax Avoidance Aspects of Financial Transactions
Author: Piergiorgio Valente
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The OECD Issued 13 Peer Review Reports on Transparency and Exchange of Information for Tax Purposes
Author: Piergiorgio Valente
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Transfer Pricing and Related Parties Disclosures
Author: Piergiorgio Valente
To ensure the respect of the arm’s length principle, Italian Law manda...
Corporate Tax Residence and Tax Avoidance. The Perspective of Italian Tax Administration
Author: Piergiorgio Valente and Ivo Caraccioli
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The OECD Action Plan on Aggressive Tax Planning
Author: Antonella Della Rovere
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Erosion of the Taxable Base and Profit Shifting: the OECD Action Plan
Author: Caterina Alagna and Federico Vincenti
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Counteracting Tax Evasion
Author: Antonella Della Rovere
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Models for Tax Exemption and Refund
Author: Salvatore Mattia and Federico Vincenti
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Tax Agreement Between Italy and Switzerland: the Ongoing Debate
Author: Salvatore Mattia and Federico Vincenti
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Italy Launches Large Taxpayers Pilot Program
Author: Salvatore Mattia
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Transfer Pricing: the Relation between Arm’s Length and Customs Value
Author: Piergiorgio Valente and Salvatore Mattia
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Statistics From Italy’s APA Program
Published in: Tax Notes Int’l, July 8, 2013
On March 19, the Italian Revenue Office published the ...
Base Erosion and Profit Shifting: Developments at the OECD Level
Author: Caterina Alagna
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Banking Permanent Establishment’s Endowment Funds: Requirements and Critical Issues
Author: Piergiorgio Valente
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Financial Transaction Tax: Updates at the EU Level
Author: Piergiorgio Valente
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OECD Updates on Base Erosion and Profit Shifting
Author: Salvatore Mattia
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Highlights of the Hong Kong-Italy Income Tax Agreement
Authors: Piergiorgio Valente, Caterina Alagna
In a press release dated January 14, 2013, the Italian...
Burden of Proof in Transfer Pricing: Recent Case Law
Author: Piergiorgio Valente
A few decisions taken in recent years by the Italian Courts have shed so...
The Convention between Italy and San Marino to Be Ratified Soon
Author: Piergiorgio Valente
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Non-deductibility of Costs for Operations Carried Out with Companies Residing in Privileged Tax Regimes
Author: Salvatore Mattia
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The EU Platform for Tax Good Governance, Aggressive Tax Planning and Double Taxation
Author: Caterina Alagna
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The EU Commission Establishes a New Working Group on Tax Good Governance
Author: Antonella Della Rovere
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Italian Regional Production Tax and Its Impact on Taxpayers
Author: Piergiorgio Valente
IRAP is a regional production tax (established by Legislative Decree No....
Transfer Pricing: Comparability Criteria and Benchmark Analysis
Author: Piergiorgio Valente
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Operating Base and Taxation for Foreign Airline Companies Operating in Italy
Author: Raffaele Rizzardi and Salvatore Mattia
Article 38 of the so-called Development Decree provid...
New Rules on “Safe Harbours”
Author: Piergiorgio Valente
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Actions for Contrasting Tax Fraud and Tax Evasion
Author: Piergiorgio Valente
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Transfer Pricing: the OECD Approves a Revised Text on “Safe Harbours”
Author: Salvatore Mattia and Federico Vincenti
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Managers are Allowed to Require Fees to the Parent Company
Author: Maurizio Meoli
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Transfer Pricing Declaration Duties
Author: Piergiorgio Valente and Salvatore Mattia
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The International Model of Taxpayer Charter Developed by the CFE, AOTCA and STEP
Author: Caterina Alagna
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False Statements: Updates in Case Law
Author: Maurizio Meoli
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Model Taxpayer Charter: Proposals by the European Commission
Author: Piergiorgio Valente
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Permanent Establishment and Jurisdiction to Tax: the International Debate
Author: Piergiorgio Valente
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Transfer Pricing Risk Assessment
Author: Piergiorgio Valente
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Italy’s Stability Law Introduces the Financial Transaction Tax
Author: Piergiorgio Valente and Federico Vincenti
Italy’s 2013 Stability Law, which became effecti...
Transfer Pricing Assessment: Selection of Taxpayers and Procedural Aspects
Author: Piergiorgio Valente
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Tax Risks Arising From Internationalization of Business
Author: Caterina Alagna and Federico Vincenti
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Convention between Italy and San Marino Approved by Italian Council of Ministers
Author: Caterina Alagna and Salvatore Mattia
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Intercompany Loans. The Position of Lombardia Regional Tax Commission
Author: Piergiorgio Valente and Salvatore Mattia
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Tax Residence, Fictitious Interposition and Treaty Shopping
Author: Caterina Alagna and Federico Vincenti
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Tax Planning and Base Erosion
Author: Caterina Alagna and Federico Vincenti
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New Model for the Exchange of Information among EU Countries
Author: Caterina Alagna
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Automatic Exchange of Information: the New Multilateral Agreement Model
Author: Piergiorgio Valente
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International Procedures for Dispute Settlement: OECD Updates
Author: Piergiorgio Valente
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Tax Residence of Legal Persons in Some EU and non EU Countries
Author: Piergiorgio Valente
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Italy – An Outlook on the Supreme Court’s Transfer Pricing Decisions
Author: Piergiorgio Valente
Transfer pricing litigation in Italy is becoming increasingly common.
No...
Automatic Exchange of Information as a Tool for Fighting Tax Evasion within the EU
Author: Piergiorgio Valente and Caterina Alagna
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CFE Forum 2013 – Tax Planning: Critical Issues and Opportunities
Author: Caterina Alagna and Federico Vincenti
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Official Bulletin on International Tax Ruling in Italy
Author: Piergiorgio Valente
On March 19 2013, the Italian Revenue Office published the second editio...
Arm’s-length Value of Royalties: Italian Case Law
Author: Piergiorgio Valente
The international transfer pricing of goods and services between associa...
Italy’s Measures Against Tax Evasion And Aggressive Tax Planning
Author: Piergiorgio Valente and Federico Vincenti
The OECD suggests that the search for effective ac...
Anti Money Laundering Complaints for All Kind of Crimes
Author: Ivo Caraccioli
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EU Recommendations on Aggressive Tax Planning and Tax Good Governance
Author: Piergiorgio Valente
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Aggressive Tax Planning. The OECD Report “Addressing Base Erosion and Profit Shifting”
Author: Piergiorgio Valente
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Comparability Analyses and Criteria for Selection: Why the Italian Tax Authorities Need More Evidence in Court
Author: Piergiorgio Valente and Federico Vincenti
Transfer pricing has been the subject of a number ...
Transfer Pricing Audit: Italian Approach
Author: Piergiorgio Valente and Federico Vincenti
In recent years the complexity and importance of t...
Transfer Pricing Year-end Adjustments
Author: Piergiorgio Valente
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Small and Medium Enterprises and Cost Contribution Arrangements: the Position of the EU Commission
Author: Piergiorgio Valente
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The OECD Focuses on “Aggressive Tax Planning”
Author: Piergiorgio Valente and Caterina Alagna
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Tax Rates: Updates on Trends in EU Member States
Author: Piergiorgio Valente
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Relocation Abroad as a “Fictitious Operation”
Author: Piergiorgio Valente and Caterina Alagna
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Falciani’s List: Italian Case Law
Author: Piergiorgio Valente
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Year-end Adjustments: the Italian Perspective
Author: Piergiorgio Valente
In matters of transfer pricing, the terms “compensating adjustments”...
The “Place of Prevailing Economic Interest” as Main Criteria for Identifying Tax Residence
Author: Piergiorgio Valente
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Beneficial Owner Provisions: Amendment Proposals
Author: Piergiorgio Valente
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A 26 European Country Agreement on the Tobin Tax Seems Likely
Author: Piergiorgio Valente
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Transfer Pricing Audits: Position of the Italian Courts
Published in: Intertax – Volume 41 January 2013
The Italian Tax Authorities encounter difficul...
Tax Offences in Search of Definition
Author: Ivo Caraccioli
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Case Law on the Usability of Falciani’s List
Author: Salvatore Mattia and Caterina Alagna
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International Cooperation and EU Principles in the Field of Fight against Tax Fraud, Tax Evasion and Aggressive Tax Planning
Author: Piergiorgio Valente
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Deductible Expenses and Freedom to Provide Services
Author: Piergiorgio Valente
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EU Commission Proposals on Aggressive Tax Planning
Author: Piergiorgio Valente
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Opinion Statement of the CFE on the OECD Discussion Draft “Proposed Revision of the Section on Safe Harbours in Chapter IV of the OECD Transfer Pricing Guidelines”
Author:
Comments on the Discussion Draft “Proposed Revision of the Section on Safe Harbours in Cha...
Transfer Pricing: Valuation of Intangibles and Simplification – A Summary of Key Issues at the International Level
Author: Piergiorgio Valente
In this note, the elected Chairman of the Fiscal Committee of the CFE, M...
The Convention between Italy and San Marino Has Been Ratified
Author: Salvatore Mattia and Caterina Alagna
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“Transfer Pricing Policy” and Economic Recession
Author: Piergiorgio Valente
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The Necessity to Adjust the Tax Treatment of Dividends
Author: Piergiorgio Valente
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Cross-Border Shares’ Exchange and Freedom of Establishment
Author: Piergiorgio Valente
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State by State Statistics on the Mutual Agreement Procedure (Art. 25 of the OECD Model)
Author: Piergiorgio Valente
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56th UIA Congress Dresden – International Negotiation for Lawyers Commission
Author: Filipa Correia
“In Business and in Life, you don’t get What you Deserve, you Only get Wh...
Transfer Pricing: Comparability Analysis Based on the Specificc Case
Author: Piergiorgio Valente
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The UN Manual on Transfer Pricing in Developing Countries
Author: Piergiorgio Valente
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Company Merger: the Mere “Suspect of Avoidance” is not Enought
Author: Salvatore Mattia
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Disputes Relating to Transfer Pricing: the Case Law
Author: Piergiorgio Valente
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San Marino Tax Reform
Author: Piergiorgio Valente and Luca Beccari
Within an international economic context marked by a st...
The Court of Cassation Case Law on Transfer Pricing
Author: Piergiorgio Valente
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From Abroad 6/2011
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The Conditions for Setting up a Permanent Establishment
Author: Salvatore Mattia and Caterina Alagna
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Changes Brought by the Enabling Law and the Development Decree Law
Author: Salvatore Mattia and Federico Vincenti
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The Italy-San Marino Treaty and the New Protocol of Amendement
Author: Luca Beccari and Salvatore Mattia
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Countering Aggressive Tax Planning
Author: Piergiorgio Valente
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The network of Tax Information Exchange Agreements (TIEA)
Author: Piergiorgio Valente and Luca Beccari
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The Conventional Network of San Marino
Author: Piergiorgio Valente and Luca Beccari
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The San Marino Legislation on the Fight Against Money Laundering
Author: Piergiorgio Valente and Luca Beccari
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The “Black List” Communications in Trades With San Marino
Author: Luca Beccari, Fabrizio Cremoni and Salvatore Mattia
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Affordability Prevails Over Contractual Anomalies in Intercompany Loans
Author: Salvatore Mattia and Claudio Melillo
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Banckruptcy by Fraudolent Accounting: Only if Thresholds are Exceeded
Author: Maurizio Meoli
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Italian Taxation of Hidden Permanent Establishments
Author: Piergiorgio Valente
The Italian Income Tax Code (Testo Unico delle imposte sul reddito, or T...
Transfer pricing and Intangibles: the OECD Discussion Draft of June 6, 2012 on the So Called “Safe Harbors”
Author: Piergiorgio Valente
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«Transfer Pricing» and Loan Agreements: the Adequacy of Interest Rates
Author: Piergiorgio Valente
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Italy Ratified the Treaty on Stability, Coordination and Governance in the Economic and Monetary Union
Author: Piergiorgio Valente and Caterina Alagna
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Fight Against Tax Fraud, Proposal to Amend the Directive 112/2006
Author: Salvatore Mattia and Caterina Alagna
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Automatic Exchange of Information and Confidentiality in the OECD Reports
Author: Piergiorgio Valente
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A New International Model of Tax Treaty is Adopted
Author: Piergiorgio Valente
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Deflationary Litigation Tools and Adhesion to PVCs: Critical Profiles
Author: Piergiorgio Valente and Roberto Betti
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Intra-Community VAT Contextual to the Application to the VIES
Author: Marco Peirolo
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Italian Rules Regarding Disputes of Transfer Pricing Violations
Author: Piergiorgio Valente
Italian tax rules regarding disputes for transfer pricing violations are...
Update on Art. 26 of the OECD Model
Author: Piergiorgio Valente and Caterina Alagna
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Transfer Pricing and Double Taxation: Solutions According to the EC
Author: Piergiorgio Valente
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Double Non-Taxation: the Results of the Consultation With the EU Commission
Author: Piergiorgio Valente and Caterina Alagna
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Criminal Liability of Professionals in Corporate Crisis
Author: Ivo Caraccioli and Maria Saveria Del Vecchio
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The Treaty Against Double Taxation Italy – San Marino: Protocol of June 13, 2012 Brings News
Author: Piergiorgio Valente
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Pensions Paid by Foreign Institutions to Residents of Italy
Author: Piergiorgio Valente
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The Agreement Italy – Jersey on Information Exchange
Author: Piergiorgio Valente and Caterina Alagna
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The Declarative Obligations on Transfer Pricing
Author: Piergiorgio Valente
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“Transfer Pricing” in “Cash Pooling” and Factoring Contracts
Author: Piergiorgio Valente
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Mutual Agreement Procedures to Resolving International Tax Disputes
Author: Piergiorgio Valente
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Fight Against Tax Evasion: the Proposal to Amend the Directive 2011/16/EU
Author: Piergiorgio Valente
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Transfer Pricing: the Analysis of Functions Assets and Risks
Author: Piergiorgio Valente
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Convention Between Italy and San Marino: Signed the Protocol of Amendement
Author: Piergiorgio Valente
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Italy and San Marino Sign Tax Treaty Protocol
Author: Piergiorgio Valente and Luca Beccari
Italy and San Marino on June 13 signed a protocol to th...
Italy – San Marino: Signed the New Protocol of Amendment
Author: Piergiorgio Valente
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The «Hidden» Permanent Establishment in Italian Case Law
Author: Piergiorgio Valente
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The Clarification of the Tax Authorities Concerning Mutual Agreement Procedures
Author: Piergiorgio Valente
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The Financial Transaction Tax in the EU Debate
Author: Piergiorgio Valente
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Tax Disputes Between States: the Agency Clarifies the Mutual Agreement Procedure
Author: Salvatore Mattia and Caterina Alagna
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Transfer Pricing: Tax Audits in the Report of the Forum on Tax Administration
Author: Piergiorgio Valente
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Tax Crimes and Confiscation per Equivalent
Author: Ivo Caraccioli
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Transfer pricing and the Ford Italia case
Author: Piergiorgio Valente
The last decade saw a significant increase of transfer pricing controver...
Ruling National Grid Indus BV: the Exit Tax in the Case of Transfer Abroad
Author: Piergiorgio Valente and Caterina Alagna
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The European Commissioner on the Rubik Agreements They Are in Compliance With the Community Law
Author: Piergiorgio Valente
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Updates on Accounting Fraud
Author: Ivo Caraccioli
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The Revision of the “Savings Directive” n. 2003/48/EC: News, Issues and Recommendations
Author: Piergiorgio Valente
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The Assessment of Administrative Liability of Public Entities
Authors: Antonio De Luca and Claudio Melillo
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Aggressive Tax Planning: Review of the OECD Report on the Initiatives of Tax Governance
Author: Piergiorgio Valente
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Switzerland’s Agreements with Germany and the UK: the Relations with the Provisions of the “Savings Directive”
Author: Piergiorgio Valente
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OECD Model: Employees of the Permanent Establishment
Author: Piergiorgio Valente
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Directive n. 90/434/EEC and the Notion of Valid Economic Reasons
Authors: Piergiorgio Valente and Caterina Alagna
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Cabinet Approves Draft Tax Reform Bill
Author: Piergiorgio Valente
Italy’s Council of Ministers (Cabinet) on April 17 approved the Draft...
Fictius Tax Residence and Regular Residence: the Italian Transport Companies
Authors: Piergiorgio Valente e Salvatore Mattia
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The Italian Tax Policy in the European Context Today
Author: Raffaele Rizzardi
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Critical Issues: in the Discipline of Dividend Flows in the Recast of the Parent-Subsidiary Directive
Author: Piergiorgio Valente
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The Hybrid Mismatch Arrangements: Conclusions and Recommendations of the OECD
Author: Piergiorgio Valente
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Switzerland’s Agreements with Germany and the UK: the Issues
Author: Piergiorgio Valente
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Serious Penalties under Arbitration Convention No 90/436/CEE. Criminal Aspects and Sanctions in Italian Legal System
Authors: Piergiorgio Valente and Ivo Caraccioli
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Transfer Pricing in Developing Countries: The UN Manual
Author: Piergiorgio Valente
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Open Debate on the Tax Governance
Author: Piergiorgio Valente
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Italy’s CFC Regime: Wholly Artificial Arrangements
Author: Piergiorgio Valente
In Italy the subject of controlled foreign corporations is extremely to...
OECD Model: is the Distributor Personal Permanent Establishment?
Author: Piergiorgio Valente
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Monti Decree: News on “Shielded” Assets and Property Held Abroad
Author: Piergiorgio Valente e Salvatore Mattia
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(Ir)relevance of Irap and VAT in Case of Transfer Pricing Adjustments
Authors: Salvatore Mattia e Claudio Melillo
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Andaf: White Paper on Simplification. The Contribution of the Tax Technical Committee
Author: Salvatore Mattia
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Arbitration Convention 90/436/EEC: Inapplicability in Case of Serious Penalties
Author: Piergiorgio Valente
A tool for settling transfer pricing controversies is the EU Arbitratio...
Theoretical and Substantial Suitability for the Non-Application of Sanctions in Transfer Pricing
Authors: Piergiorgio Valente e Roberto Betti
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Italy and the Transfer Pricing Issue
Author: Piergiorgio Valente
Transfer pricing is the hot topic in the tax audit world right now in I...
Serious Penalties According to the Arbitration Convention No. 90/436/EEC and Criminal Profiles and Sanctions in the Italian System
Authors: Piergiorgio Valente e Ivo Caraccioli
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From Abroad 7/2011
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Italy’s Treaties: Double Taxation and Canons/Principles
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San Marino’s Tax Information Exchange Agreement Proposals
Two decades after its last tax reform, the San Marino government has identified the reform of its ta...
The San Marino Tax Reform Proposal: the Development of the Binomial “Transparent Competitions”
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The Burden Of Proof And Transfer Pricing
This article discusses the rule on the burden of proof as laid down in Art. 2697 of the Civil Code. ...
Transfer Pricing – Criminal Tax Risks under Italian Law
Transfer Pricing – Criminal Tax Risks under Italian Law The authors examine the potential criminal...
The ‘Center of Vital Interests’: A Review of Italy’s Rules on Tax Residence
The Italian Revenue Office has been forwarding questionnaires to many individuals who, in the last f...
An In-Depth Analysis of New Transfer Pricing Documentation Rules
The purpose of this work is to provide an in-depth analysis of the topic of transfer pricing documen...
Transfer Pricing and Supply of Inter-Company Services
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Italian Guidance On Choosing The Appropriate Transfer Pricing Method
In Circular No. 58/E of December 15, 2010, the Italian tax authorities clarify how to determine the ...
CFE Fiscal Committee National Reports – September 2008 – 114th Meeting
Bill implementing Merger Directive submitted to Belgian parliament:
On July 24, 2008, the Belgian go...
Italy – Introduction of The Deemed Residence Rule and International Tax Planning
L’art. 35 co. 13 del DL 223/2006 (conv. in L. 248/2006) aggiunge i co. 5-bis e 5-ter all’...
EU Enlargement: Update on Candidates
La Commissione europea, terminato il quinto processo di allargamento (oggi l’UE conta 27 Paesi...
Taxation in the International Market and Commission Communication n° 582
The future of the corporate income tax system has now been discussed for a very long time in the Eur...
The New San Marino-Italy Tax Treaty
In data 21.3.2002, tra la Repubblica di San Marino e l’Italia, è stata firmata una convenzi...
Italy: New CFC Legislation
New provisions concerning the taxation of income generated by Controlled (CFC Legislation) have rece...
The New Italy-US Tax Treaty
A new treaty between the United states and Italy (hereinafter: the new treaty) was signed in Washing...
The New Tax Credit Regime on Dividends: Effects on Existing Treaties
The aim of this article is to outline the provisions introduced in Italy by the Legislative Decree N...
Fiscal Aids: (In)Compatibility with EU Rules ?
Tax aids garanted by EU member states to some enterprises to specific territorial areas are, along w...
Italian Tax Reform: Eligibility of New Taxes for U.S. Foreign Tax Credit
In connection with the issuance of Public Law 662/1996 last December (1997 Finance Act), the italian...