Permanent establishment through related corporations : new case law in Italy and its impact on multinational flows

Journal
Gazzo, M.
Bulletin for International Taxation 2003 (Volume 57), No. 6
PriceUSD 45

The complexity and statelessness of the new organizational form of multinational enterprises have revitalized the traditional international tax concepts such as "tax residence" and "permanent establishment". After briefly considering the permanent establishment concept in Italy, discussion of the recent decisions of Italy's Supreme Court on the PE issues of an multinational enterprise in Italy known as the "Philip Morris case"