On 19 November 2024, the Italian Tax Authority (ITA) published Circular Letter No. 23/E (Circular) aimed at providing clarifications on the Investment Management Exemption (IME) regime, following its introduction in Article 162 of the Italian consolidated income tax code (ITC) and the subsequent implementing Ministerial Decree (Decree).The Circular provides much-needed clarifications on some specific requirements for applying the IME regime, such as the independence requirement for foreign investment vehicles and for asset/investment manager/advisory companies.The Circular also contains specific commentary on the scope of transfer pricing guidelines on applying the arm's-length requirement to asset management transactions and on the qualifying documentation...