Italy:
New Decree Expands The Scope Of The International Ruling Procedure
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The Decree Law No. 145 of December 23, 2013 (ratified by Law No.
9 of February 21, 2014) broadens the scope of the international
ruling procedure. The main area of application is transfer pricing,
in particular advance pricing agreements, but it may also apply to
(i) the attribution of income or losses to Italian permanent
establishments of nonresident taxpayers and to foreign permanent
establishments of Italian-resident taxpayers, or (ii) the
application of tax treaties to dividends, interest, and royalties.
Rulings issued under this procedure are binding on the taxpayer and
the tax administration for the tax year in which they are issued
and the following four years (two years under the regime applicable
before the recent amendment).
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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