By way of thirteen decisions issued in June and July (numbers 15451, 15453, 15455, 15456 of June 7, 2019, numbers 16699, 16700, 16701, 16702, 16703, 16704, 16705 of June 21, 2019, no. 19167 of July 17, 2019 and no. 19319
Marco Q. Rossi & Associati
Marco Q. Rossi & Associati is a legal organization that publishes content related to various areas of law. The firm provides insights and updates on legal matters, likely focusing on topics relevant to their practice areas. Their publications serve to inform clients and the public about legal developments, regulatory issues, and practical legal advice. The content is typically aimed at professionals and individuals seeking legal information or representation.
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Latest from Marco Q. Rossi & Associati - Page 5
Italian Tax Agency Rules on Merger Leveraged BuyOut, Denies Interest Withholding Exemption Under Beneficial Ownership Clause
By Marco Rossi
With its tax ruling n. 88/E of October 18, 2019 (Ruling 88-2019), the Italian Tax Agency denied the interest withholding tax exemption provided for in the EU Interest and Royalties Directive, in respect of interest due by an…
Holding Company’s Tax-Free Reorganization Does to Jeopardize Dividend Withholding Exemption, Italy’s Tax Agency Rules
By Marco Rossi
In its Ruling N. 380 of September 11, 2019, Italy’s Tax Agency provided its guidance on certain tax implications of a corporate reorganization pursuant to which a Luxembourg holding company, which owns an Italian company, would reincorporate into Switzerland…
Italian Tax Agency Rules on Tax Effects of Early Termination of Trust, Treats It As Gift Back to Settlor Subject to Gift Tax
By Marco Rossi
In its Private Letter Ruling n. 355 of August 30, 2019 the Italian Tax Agency considered the tax implications, for Italian gift tax purposes, of a transaction involving the early termination of an irrevocable trust by way of mutual consent…
Italian Tax Residence For Individuals: A Refresher And Look At Open Issues And New Matters
By Marco Rossi
Italian tax residence is a very important topic for foreign nationals who travel regularly to Italy, own houses and spend significant time with their family there, while living and working abroad, as well as for those who relocate to Italy…
Italian Substituted Tax On Financial Income At Odds With Tax Treaties
By Marco Rossi
Italy taxes various categories of financial income – namely dividends, interest and capital gains – earned by private investors outside the carrying on of a trade or business, by way of a substitute tax charged on the gross amount of…
The Italian Tax Agency Clarifies The Meaning of Beneficial Owner For Purposes of International Tax Reporting of Foreign Assets Held in Trust
By Marco Rossi
With its resolution n. 53/E issued on May 29, 2019 the Italian tax agency issued some important clarifications on the exact scope of the Italian international tax reporting rules in case of foreign assets held through trusts, foundations or similar…
Italian Tax Court Rules Against The Use Of Unit Link Insurance Policy For Tax Avoidance Purposes
By Marco Rossi
With its decision n. 5608 of December 10, 2018 the Italian Provincial Tax Court of Milan ruled against the (ab)use of so called “unit linked” life insurance policies for tax avoidance purposes.
The decision of the tax court refers to…
Italian Tax Agency, Taxpayer Settled The Biggest “Silent” Permanent Establishment Tax Case For a Record Amount of 1.250 Billion Euro In Taxes And Penalties
By Marco Rossi
The Italian financial newspaper “Il Sole 24 Ore” reported today that Koering, the French-owned conglomerate which controls some of the most renowned and revered luxury brands in the world, such as Gucci, Bottega Veneta, Saint Laurent, Pomellato and others associated…
Italy’s Regional Tax Court Denies Dividend Withholding Tax Exemption In the Absence Of Actual Taxation In the Country of Residence
By Marco Rossi
By way of ruling n. 55/6/2019 filed on January 21, 2019, the Regional Tax Court of Abruzzo held that no withholding tax exemption under the EU Parent-Subsidiary Directive applies, unless the EU parent company proves that it has been “materially…