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International Tax Planning - International Law Firm

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Our tax team has acquired significant experience in providing advice on income derived from international transactions, including activities carried by Italian companies wishing to expand their activities abroad and foreign investors looking to invest in Italy. 

Our experts are constantly involved in assisting on issues related to BEPS, Pillar 1 and Pillar 2.

In particular, we have extensive experience in the identification and determination of a permanent establishment and the related methods of determining income, the definition of international dividends, interest and royalties, cost-sharing agreements, CFC legislation, anti-avoidance legislation, and hybrid financial instruments.

Our Firm boasts an outstanding and experienced group of professionals dedicated to transfer pricing.


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08/04/2024
New obligation to apply withholding taxes on commissions received by agents...
With Circular letter no. 7/E of March 21, the Italian Revenue Agency provided some clarifications in relation to the new obligation to apply withholding taxes on commissions received by agents and other...
Newsletter
06/02/2024
Razion­alizza­zione e semplificazione delle norme in materia di adempimenti...
1.  Novità in tema di dichiarazioni fisc­ali1.1.     Revisione dei termini di presentazione delle dichiarazioni fiscali (art. 11)1.2.     Esclusione della decadenza dal beneficio in caso di mancata...
Newsletter
27/12/2023
No white smoke on ATAD III proposal in 2023
As a reminder, on 22 December 2021, the European Commission issued its proposal for a directive to prevent the abuse of shell entities for tax purposes (ATAD III proposal). After several amendments, the...
Law-Now Tax
24/11/2023
Carbon Border Adjustment Mechanism transition in effect since 1 October...
On 1 October 2023, a two-year transitional period began for implementation of Regulation (EU) 2023/956, which introduces the Carbon Border Adjustment Mechanism (CBAM). CBAM levies punitive CO2 charges...
Law-Now Carbon Border Adjustment Mechanism (CBAM)
09/11/2023
Identification of the beneficial owner of Italian companies | What you...
As it is known, by 11 December 2023, all “enterprises having legal personality that must be registered in the Companies Register” (companies, legal persons, funds, trusts, trust companies, etc.) shall...
Law-Now Tax
09/11/2023
Restyling of the tax regime applicable for individuals transferring their...
Based on draft legislation approved by the Italian government on 16 October 2023, the tax relief for impatriate individuals (“the Impatriate regime”) may potentially be subject to a major overhaul...
Law-Now Tax
09/11/2023
Identification of the beneficial owner of Italian companies
As it is known, by 11 December 2023, all “enterprises having legal personality that must be registered in the Companies Register” (companies, legal persons, funds, trusts, trust companies, etc.) shall...
Publication
07/11/2023
Global Wealth and Tax Planning
CMS Country Tax Guide provides preliminary information on the main tax features for 13 jurisdictions for high net-worth individuals, entrepreneurial families, their advisors and family offices in connection...
Expert Guide Tax
Comparable
11/10/2023
Doppio binario per l'applicazione del monitoraggio CFC
09/10/2023Il Fisco n. 38/2023Nel Modello di dichiarazione Redditi SC 2023 (periodo di imposta 2022) e nelle relative istruzioni si osser­va una significativa novità per ciò che riguarda il c.d. meccanismo...
Publication
27/09/2023
DAC 8 Proposal approved by the European Parliament
BackgroundIn recent years, the crypto-asset landscape has steadily grown and has reshaped the world of payments and investments. Today such assets have an estimated market capitalization of USD 1.09 trillion...
Law-Now Tax
24/07/2023
The decision of the Supreme Court on the taxation of capital gains on “sig­ni­fic­ant...
The Supreme Court with the decision No. 21261 of 19 July 2023 has acknowledged the illegitimacy of the Italian tax regime applicable to capital gains deriving from the transfer for consideration of a...
Newsletter
06/03/2023
Decreto Milleproroghe 2023: le principali novità in ambito fiscale e societario...
Newsletter
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