Italy: Qualification of software distribution payments as royalties or business profits
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente explain how Italy classifies payments for software distribution and the potential consequences in the event of a tax audit.
The importance of intangible assets in the value creation process of multinational groups, and their ability to generate profits, underscores the need for careful analysis of their tax treatment. The unique characteristics of intangible assets present inherent challenges in both identifying them and determining their value.
- January 13, 2026
authors:
Carola Valente Della Rovere
International Liaison Manager and Strategic TP
Federico Vincenti
TP Partner

