Italy Tax News

Protocol to treaty between Malta and Italy signed

10 April 2009

Italian tax authorities ruling that CFC regime applies when indirect participation, via transparent entity (France) and trusts, in companies resident in black list countries (Isle of Man, Mauritius)

23 January 2009

Treaty between Iceland and Italy enters into force

24 December 2008

ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies resident in other Member States justifiable restriction on EC freedom of establishment – details

4 November 2008

Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages

4 November 2008

Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)

4 November 2008

ECJ: Advocate General finds Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details

4 November 2008

ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment

7 October 2008

Treaty between Italy and Iceland ratified

7 October 2008

OECD released 2008 Model Tax Convention

7 October 2008

Discussion draft on New Art. 7 of OECD Model – details

30 August 2008

OECD Council approves 2008 Model Tax Convention

11 August 2008

Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax

11 August 2008

Treaty between Latvia and Italy enters into force

27 July 2008

Treaty between Italy and Belgium – Italian tax authority rules on tax qualification of payments under non-competition agreement

27 July 2008

Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008

European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

21 June 2008

ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details

21 June 2008

European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

21 June 2008

ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

21 June 2008

ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

21 June 2008

Treaty between Italy and Latvia – ratified by Italy and details

21 June 2008

ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

21 June 2008

Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008

CFC rules apply to Italian company with subsidiary and branch in black listed country, even if actual business activity carried on

21 June 2008

Treaty between Italy and Tunisia – Italian tax authorities rule on whether domestic tax credit is available on portion of prélèvement fiscal global

14 May 2008

ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

14 May 2008

Dividends and capital gains: new percentage of exemption

14 May 2008

European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax

14 May 2008

Merger of UK companies with Italian PEs: tax consequences

16 March 2008