Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici consider what to expect with regard to global minimum tax reporting obligations following the implementation of the side-by-side package
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici analyse the recent amendments to the Italian tax regime governing intercompany dividends and assess their likely impact on international investment structures
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici examine key issues in Italy’s transposition of DAC8 and the challenges posed by technological transformation in the digital economy
Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status
Paolo Ludovici, Andrea Iannaccone, and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici assess whether Italy’s reforms meet European Court of Human Rights standards on safeguards for inspections of homes and business premises
