Hager & Partners

Italy has implemented a growth decree designed to encourage research & development (R&D). Hager & Partners' Gian Luca Nieddu and Barbara Scampuddu discuss the key tax implications of the decrees 32 articles.

On 28 December 2018, the Italian government published Legislative Decree No. 142, transposing the European Union's Anti-Tax Avoidance Directive (2016/1164) into Italian legislation. The new set of provisions will be effective from the fiscal year following December 31 2018. The decree will aim to tackle tax avoidance practices related to interest deduction, exit tax, rules on foreign controlled companies, a definition of financial intermediaries, and hybrid mismatches, all of which are explored below.

A ruling issued on November 2 2018 by the Central Revenue has provided clarification regarding the application of the VAT regime to transfer pricing (TP) year-end adjustments occurring between related companies belonging to the same multinational group (group).