This section includes national tax rules for private equity and venture capital. In particular, this section contains the interpretative circulars of the Italian Revenue Agency, EU and international taxation, as well as notes on topical issues.
Cross-border home working: a taxable presence for employers?, by Toni Marciante (Freshfields)
Italian Supreme Court decision (no. 25490 of 10 October 2019): potential issues for EU holding companies receiving dividends from their Italian subsidiaries in cases where transactions fall within the scope of the EU Parent-Subsidiary Directive, by Roberto Romito (Fieldfisher)
LBOs (mergers) and deductibility of interest expenses: interesting developments with Italian Supreme Court decision of July, by FT Private Equity, Authors: Stefano Brunello and Paolo Ronca (BonelliErede)
VAT deductibility of transaction costs incurred in the context of leveraged buyouts - latest European positions and potential effects on the Italian Tax Authority's view as expressed in Circular Letter No. 6/E of 30 March 2016, by Luca A. Pangrazzi and Matteo Poletti (Fieldfisher)
The (non-public) response to request no. 956-39/2018: tax regime applicable to cryptocurrencies held by individuals resident in Italy, by Fabrizio Cancelliere and Armando Tardini (Tremonti Romagnoli Piccardi e Associati)
Private Ruling no. 954-127/2017: availability of the notional interest deduction on equity injections in the context of private equity transactions, by Roberto Egori and Toni Marciante (Freshfields Bruckhaus Deringer LLP)
Direct lending - Tax exemption regime provided for outbound interests related to some medium/long-term loans granted by foreign institutional investors to Italian legal entities. New opportunities for investment funds? By Luca A. Pangrazzi and Matteo Poletti (Fieldfisher)