1. Boundaries to the application of the Italian black-list costs provisions With its decision no. 2960 of 1 February 2024, the Italian Supreme Court ruled that the non-deductibility regime of
1. Beneficial ownership requirements under the Interest&Royalty Directive According to the Italian Supreme Court decision no. 510 and 521 of 8 January 2024: in the context of the Interest&Royalty Directive
Previous rules on tax residence of legal entities Art. 73 of the TUIR stated that companies were considered to be tax resident in Italy if, for the greater part of
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