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 “black-list” costs under Article 110(9-bis) and ff. of the TUIR cannot be presumptively invoked by the Italian Tax Authorities merely … Read more
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 (Directive 2003/49/EC), the notion of beneficial owner is to be understood as a substantive rule aimed at allocating taxing power, … Read more
ROME
MILAN
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