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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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties