Selected Issues Regarding the New Italian Exit Tax Rules

Journal
Caltagirone, L.; Villa, R.
Italy
European Taxation 2022 (Volume 62), No. 8
PriceUSD 45

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.