Piergiorgio Valente

Published in: IAFEI Quarterly 36th Issue, April 2017 The Decree of the Italian Ministry of Economy and Finance for the implementation of Country-by-Country reporting (hereinafter, “CbCR”) in Italy was issued on 23 February 2017. The latter provided for reporting obligations…

Published in: Intertax 45.4 Fictitious corporate tax residence is a primary concern for States, in view of the fact that it impacts – directly and incisively – on States’ taxing rights, and also since it is known to trigger double…

Published in: Journal – Intertax (Issue 45.3) The release of the Multilateral Instrument constitutes an important step towards the most significant re-write of international tax rules in a century. It is the multilateral convention enabling the simultaneous amendment of more…

On 16 February 2017 the Public Consultation on the proposed introduction of rules at EU level to disincentivize promotion of aggressive tax planning schemes was closed. The rules under consideration focus on a Mandatory Disclosure Regime (MDR) – referred to…

Published in: IAFEI Quarterly 35th Issue The international tax system is undergoing complete renovation. Base erosion and profit shifting (BEPS) is the evil that must be curbed, reduced, most desirably totally eradicated on a worldwide scale. To this end, the…

Published in: Tax Notes Int’l, Jan 30 2017 Tax rulings and advance pricing agreements are making headlines. The European Commission is undertaking unprecedented investigations into member states’ APAs with multinationals and has recently invalidated several of them based on fiscal…

Italy has embarked upon the challenging task of redesigning its tax system. The Act of late November 2016 (hereinafter, “Act”) constitutes a best-practices example, or at least for our Country. The above Act illustrates the national fiscal policy for the…