On 7 November 2006, the Italian tax authority issued Ruling No. 124/E which deals with the tax consequences of the liquidation of an Italian permanent establishment (PE).
(a) Facts. A UK insurance company in 1992 started to carry out insurance activity in Italy under the freedom to provide services (i.e. without a branch). In 1997, the UK insurance company established a branch to extend insurance activities in Italy; consequently, the UK insurance company carried out…
OrbitaxRuling on consequences of liquidation of Italian PE
