The Italian Revenue Agency has sent an encouraging signal offering companies planning to make investments an “early” tax ruling of future treatment, making good on pledges that it is open to cooperative compliance and preventive collaboration.
So far, 16 companies have asked for a ruling, and six have filed official paperwork (three of which are foreign).
The (cultural) challenge is now to transmit this message “from the centre to the periphery.” Since real fiscal reforms are not on the table, it would be already be strong progress to create a shared juridical sensitivity with a view to bring about a more relaxed relationship between the Revenue Agency and taxpayers.
The ruling on new investments according to Article nr. 2 of D.Lgs 147/2015 is a symbol of “a friendly revenue agency” shaking hands with the investor who illustrates his business plan and the transactions necessary (transfers of business units, mergers, spinoffs, etc.) to implement it, receiving a ruling on the tax profile of the investment that nullifies any sort of fiscal uncertainty later on down the line. [Continue reading]
by Christian Montinari and Antonio Tomassini