On 26 September 2016, the Italian tax authority issued Circular No. 39/E, which clarifies the changes in the restrictions on the deductibility of payments made to residents of blacklisted jurisdictions (tax havens). The Circular summarizes the restrictions and requirements, which generally apply as follows:
- Through 2014, payments to listed jurisdictions are generally not deductible unless the taxpayer provides proof of the business substance of the transactions and that they were actually ex…