Italian Tax Authority circular letter provides clarifications on Investment Management Exemption regime

26 November 2024|Tax Alerts, National/Federal Taxation, Transfer Pricing, Asset Management, Global|Italy

On 19 November 2024, the Italian Tax Authority (ITA) published Circular Letter No. 23/E (Circular) aimed at providing clarifications on the Investment Management Exemption (IME) regime, following its introduction in Article 162 of the Italian consolidated income tax code (ITC) and the subsequent implementing Ministerial Decree (Decree).
The Circular provides much-needed clarifications on some specific requirements for applying the IME regime, such as the independence requirement for foreign inves…

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