INTERNATIONAL TAX FOCUS – MARCH 2024

Ciccioriccio-Associati-PDF-Tax-Alert

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

INTERNATIONAL TAX FOCUS – FEBRUARY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

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

Tax residence of legal entities

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 the fiscal year, alternatively: their legal seat was located in Italy; they were administered in Italy; the main object of … Read more

Tax residence of individuals

Previous rules on tax residence of individuals Based on the previous reading of the law (art. 2 of the TUIR), an individual was considered to be tax resident in Italy if, alternatively; was enrolled in the Italian Register of the resident population (AIRE); had his/her domicile in Italy, being the … Read more

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INTERNATIONAL TAX FOCUS – JANUARY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1. Increase of the Italian estate taxes on foreign assets Law no. 213 of 30 December 2023 (Budget Law for 2024) provided for an increase in estate tax rates on foreign properties. In particular, as of 2024, IVIE’s rate increases from the previous 0.76% to 1.06%; IVAFE’s rate increases from … Read more

Fiscal decree accompanying the Budget Law 2020

Fiscal decree accompanying the Budget Law 2020

Legislative Decree no. 124 of October 26th, 2019 (Tax Decree), which accompanies the 2020 Budget Law, has been published in the Official Gazette and is already in force. Following the approval of the Council of Ministers on October 16th, 2019, a number of important changes have been introduced into the … Read more

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Opening of a new office in Milan.

To crown its growth, Ciccioriccio e Associati is pleased to announce the opening of a new office in Milan in order to improve and implement its ability to assist its clients in corporate, tax and administrative matters, ensuring the best professional assistance. The Milan office is in addition to the … Read more

From Accountants and Confindustria 50 proposals for tax simplification

Simplification of legislation, rationalisation of compliance and a more balanced relationship between tax authorities and taxpayers. The document containing the proposals for tax simplification drawn up by Confindustria and the National Council of Accountants and presented yesterday in Rome moves along these three lines. Fifty proposals covering five macro-areas: VAT … Read more

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Taxes: balance and advance payment to be paid by 30 September 2019

It should be remembered that for subjects who carry out economic activities for which the summary indices of fiscal reliability (ISA) have been approved and that declare revenues or fees of an amount not exceeding the established limit, the terms of the payments resulting from the tax returns, from those … Read more

Categories Tax