International Tax Rulings

Taxpayers involved in international transactions can conclude agreements with the Italian Tax Authorities concerning:

  • Transfer pricing (i.e. APA)
  • Entry or exit value of assets in case of transfer of residence in or out of Italy
  • Attribution of profits to permanent establishments (PE)
  • Existence of an Italian PE
  • Taxation of cross-border items of income (e.g. dividends, interests, royalties)

Draft 2021 Italian Budget Law

The International Tax Ruling procedure should be amended introducing:

  1. Roll-back. Taxpayers can opt to extend the agreement to previous fiscal years which are still open to tax assessment
  2. Administrative fee. The ruling request is subject to an administrative fee based on the revenues of the group:
    1. €10k if group revenues < €100m
    2. €30k if group revenues > €100m < €750m
    3. €50k if group revenues > €750m
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