Italian Revenue Agency ruling addresses permanent establishments, VAT and TP

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners report on a decision regarding the taxation of intercompany transactions based on the activities of a branch and its parent company.

Ruling No. 336, published by the Italian Revenue Agency in June 2023, pertains to the tax treatment (specifically the VAT treatment) of intercompany transactions between an Italian permanent establishment (a branch) and its foreign head office (the parent company) located in Luxembourg (a company engaged in individual portfolio management and subject to VAT in Luxembourg).


Published on: ITR (International Tax Review) – October 16, 2023
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