New Rules on International Tax Rulings for Enterprises with International Business Operations

Abstract

Recently, a number of changes were made to Italian tax law concerning international tax rulings. The new regime formally broadens the scope of the international tax ruling procedure, which – in addition to transfer pricing – may be actually used for different queries of international relevance, including the opportunity to conclude (under certain conditions, also retroactive) agreements on the effective existence in Italy of a permanent establishment of a non-resident entity.