top of page

Newsletter

International Tax Focus - January 2023

Updated: Sep 29, 2023

International Tax Focus and International Tax In-Depth - 1/2023



 

International Tax Focus January 2023

International Tax Focus January 2023

SUMMARY


ITALIAN LEGISLATION AND CASE LAW

1. 2023 Italian Budget Law has been enacted

2. Enactment of the Law Decree n0. 198/22 (so-called “Mille Proroghe”)

3. Interposed trust divided into several compartments

4. Further clarifications on the transitory regime on dividends distributions

5. Irrelevance of compensations paid to employees with contractual obligation to pass it on

6. Interaction between the Italian “horizontal” and “vertical” consolidation system

7. Proportionality of sanctions on intermediaries for certain monitoring obligations


EU LEGISLATION AND CASE LAW

8. VAT deduction related to invoices issued in the context of a VAT fraud

9. Relevant entity for VAT Group regime purposes

10. Professional privilege overrides EU administrative tax cooperation rules

11. DAC 8 Amended Directive Proposal

12. New Directive on economic and sustainability reporting

13. EU Directive 2022/2523/EU shall transpose the Pillar 2 rules into EU Law

14. VAT deduction limitations on the acquisition of motorised road vehicles and related costs


DTT/OECD/MLI

15. OECD Public Consultation on the dynamics of Amount B under Pillar One 7

16. Repealing of the transitional Covid-19 rules for Italian frontier workers in Switzerland 7

17. Agency PE features under tax treaties according to the Italian Supreme Court 7

GLOSSARY



Italy Capital Gain Taxation

New Italian Capital Gain Taxation on Real Estate Vehicles


SUMMARY


1. Foreword 2

2. Preceding regime

2.1 Portfolio Participation Exemption

2.2 Listed Participation Exemption

2.3 Irrelevance of the Sale of Foreign Entities

2.4 Tax Treaty Exemption

3. New provisions for real estate entities

3.1 Extra-territorial Taxation on Real Estate Entities Capital Gains

3.2 (Partial) Repealing of the Portfolio Participation Exemption

3.3 Interaction Between the New Italian Provisions and Tax Treaty Law

4. Glossary



 

monthly_update_january_2023
.pdf
Download PDF • 424KB

new_italian_capital_gain_taxation_on_real_estate_vehicles
.pdf
Download PDF • 371KB

bottom of page