On July 23 2004 the Italian central tax agency issued the explanatory notes (the Explanatory Notes) envisaged by article 8(2) of Law Decree 269, of September 30 2003 (Decree 269) necessary to allow certain enterprises that carry on an international activity (each an International Enterprise) to apply for the ad-hoc ruling procedure (the International Ruling Procedure) established by article 8 of same Decree 269
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The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR