New Investment Management Exemption regime in Italy - Scope and comparative aspects with the United Kingdom, Germany and France

Italy recently introduced an Investment Management Exemption regime (IME) which provides a protective framework to ensure that foreign investment vehicles (and directly or indirectly controlled entities) do not trigger a permanent establishment (“PE”) where their investment manager, operating in Italy on their behalf or for their benefit, can be assumed to be acting independently.

The protective regime eventually became fully operational on 28 February 2024 with the publication of guidelines by the Italian Tax Authorities. 

In the article, the editorial team outlines the rationale behind this new exemption regime, the requirements to be met and its interaction with general transfer pricing principles. Also the IME is compared with the UK rules, where a protective regime was introduced almost 30 years ago, and the French and German rules, where no protective regime has yet been introduced.

Read all the article here.