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Orbitax Tax News & Alerts

Italy's Tax news & updates from Orbitax and partners

Italy Tax News

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Finance Bill 2007 adopted: highlights on corporate taxation

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EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

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EU Commission requests Italy to implement the Interest and Royalties Directive correctly

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Report on Attribution of Profits to PEs released

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EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

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ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

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Ruling on consequences of liquidation of Italian PE

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ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

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Transfer pricing: burden of proof on tax administration

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Budget for 2007 – corporate taxation: highlights

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Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)

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European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

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Taxation of Australian residents performing independent services for Italian entity explained

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European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

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European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

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European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

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European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

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Thin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed

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Treaty between Peru and Italy – negotiations

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CFC rules: Council of State (Consiglio di Stato) approved implementing rules for "related entities"

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Ruling on application of EC Parent-Subsidiary Directive to trust companies

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Treaty negotiations between Saudi Arabia and Italy

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Treaty between Ireland and Italy – Irish CGT not covered

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Protocol between India and Italy – details

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Corporate immigration – Italian resident status commences on date of deregistration from Spanish register of companies and transfer of effective management to Italy

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Protocol between India and Italy signed

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Guideline on implementing EU Interest and Royalties Directive published

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On 3 November 2005 the Indian Union Cabinet gave its approval for the signing of a protocol amending the India-Italy income tax treaty of 19 February 1993. Further details of the protocol will be reported subsequently.

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Draft Budget Bill for 2006 Participation exemption regime

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Draft Budget Bill for 2006 capital losses

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