Tax treatment of derivatives embedded in hybrid financial instruments for Italian adopters of IAS/IFRS

Abstract

Since the enactment of Decree-Law 38 of 28 February 2005, a number of Italian companies have been required to adopt International Accounting Standards and International Financial Reporting Standards (IAS/IFRS). After a period of uncertainty as to the tax consequences of the adoption of the most innovative accounting rules under IAS/IFRS, the 2008 Finance Act has eventually set out specific tax provisions for Italian adopters of IAS/IFRS. This article focuses on the application of such new tax rules to derivatives embedded in hybrid financial instruments.