Paolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments
A case involving registration tax applied to a real estate contribution highlights the Italian tax framework’s inconsistency with the principles under a European directive, say Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici
The Italian Supreme Court has ruled that a natural person does not need to be actually subject to individual income tax to receive tax treaty protection, report Paolo Ludovici and Ludovica Lorenzetto of Gatti Pavesi Bianchi Ludovici
Paolo Ludovici and Daniel Canola of Gatti Pavesi Bianchi Ludovici say several issues are resolved by revised criteria regarding the tax residence of legal entities, but the increase in remote working creates complications
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici highlight recent advancements in cooperative compliance programmes at the international level, with an emphasis on the Italian tax regime amid ongoing changes in legislation
Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici argue that a decision by the Italian court violates the European freedoms in treating a non-resident taxpayer differently from resident entities without justification
Paolo Ludovici and Daniel Canola of Gatti Pavesi Bianchi Ludovici report on the extension of the creditability of foreign taxes to the Italian regional tax on productive activities, subject to the international tax treaty involved
Paolo Ludovici and Andrea Gallizioli of Gatti Pavesi Bianchi Ludovici comment on the ‘Delegation Law’ recently passed by the Italian Parliament, which provides for a broad revision of the tax residence of natural persons.
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on the evolution of multilateralism in tax treaties in the OECD context after a new agreement on a package to implement the two-pillar solution.
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici outline the issues surrounding an expected further revision of Directive 2011/16/EU on administrative cooperation in the field of taxation.
Paolo Ludovici and Pietro Bricchetto of Gatti Pavesi Bianchi Ludovici examine the most recent interpretative positions taken in Italy with regard to the taxable status and VAT deduction right of SPVs incorporated in the framework of MLBOs.
Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici describe the evolution of the country-by-country report at the OECD level and under the EU directives, and consider reporting for ESG policy purposes.