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