With Decree no.1 of January 20 2012 (Liberalisation Decree), Italy modified its exit tax regulation in accordance with the principles contained in National Grid Indus case. Under the new rule, companies resident for tax purposes in Italy which transfer their registered office to either an EU member state, Iceland, Liechtenstein or Norway can now opt, subject to certain conditions, for a deferral of the payment of the tax due on unrealised gains.
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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems