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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition