Selected Issues Regarding the New Italian Exit Tax Rules

Journal
Author
Caltagirone, L.; Villa, R.
Country
Italy
Published Date
Issue
European Taxation 2022 (Volume 62), No. 8
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this note, the authors analyse the extent to which the new Italian exit tax regime applies in the event of a qualified transfer of a branch of business characterized as the Italian permanent establishment of the foreign tax resident transferor, in relation to assets (and liabilities) that were not transferred but, at the same time, do not qualify (no longer qualify) as an Italian permanent establishment of the transferor.