Italy introduces branch exemption regime

As part of a comprehensive tax reform, the Legislative Decree no. 147/2015 (“Internationalisation Decree”) has introduced the so-called “Branch Exemption regime” which enables to exclude from Italian taxation profits and losses of a foreign Permanent Establishment. Taxand Italy provides an overview of this decree. New Rule The Italian tax resident companies may exclude the relevance … Read more

Proposed Regulations and New Audit Regime Create Uncertainty for Investment Funds

The second half of 2015 has been a busy period for partnership taxation. The Treasury issued proposed regulations under the long reserved IRC Section 1.707-2, and Congress passed a new law governing how large partnership audits will be performed. Unfortunately, the two changes when considered together may make life more difficult for many investment funds. … Read more