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HIDDEN PERMANENT ESTABLISHMENT TAX ASSESSMENTS: Practical Considerations

HIDDEN PERMANENT ESTABLISHMENT TAX ASSESSMENTS: Practical Considerations

Authors: Piergiorgio Valente and Luigi Vinciguerra

Non-resident foreign entities producing corporate income on Italian territory may register as permanent establishments (thus becoming fully subject to taxation in Italy) or may take a series of actions leading to the creation of “hidden” permanent establishments, as they operate within Italian legal entities partially-owned by foreign companies or bodies.
To eliminate this risk, each company should carry out accurate analyses and identify and abide by specific guidelines.

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