Transfer Pricing and Permanent Establishment Implications under the New Italian Investment Management Exemption Regime

This article examines the new Italian rules on permanent establishments which, under certain conditions, constitute a safe harbour preventing foreign investment vehicles from being deemed to have a permanent establishment in Italy. More precisely, it will provide an overview of the asset management and private equity industries in Europe and in Italy, along with some comments on the new investment management exemption regime and transfer pricing methods that shall be applied in cross-border internal dealings according to the Italian Revenue Agency.