ey-global-tax-policy-outlook-for-2015

Italy
2.7 Current tax policy and tax administration
leaders
• Matteo Renzi, Prime Minister
• Pier Carlo Padoan, Minister of Economy and Finance
• nue Agency
2.8 Key tax policy changes in 2014
• The main tax updates occurring in 2014 are summarized as
follows:
• Introduction of a one-off asset step-up option through
the payment of a substitute tax of 16% for amortizable
or depreciable assets and 12% for non-amortizable or
depreciable assets
• Increase of the notional interest deduction (ACE) on new
equity from 3% to 4% for 2014, 4.5% for 2015 and 4.75%
for 2016; in addition, the basis is increased up to 40% for
newly listed companies
• Interest on loans paid by Italian borrowers to certain
18 months are no longer subject to 26% withholding tax
• Extension of the scope of the 0.25% substitute tax on
medium- and long-term loans also to transfer of the credit
deriving from the loan facilities, assignment of the loan
agreements and transfer of the related guarantees
•
(dividends, interest and capital gains) from 20% to 26%
• Tax credit for new plants and equipment for the period
from 25 June 2014 to 30 June 2015 for companies
• Reintroduction of the participation step-up through the
payment of a substitute tax of 16%
•
be turned into tax credits in new instances
• Special bad debt provisions for banks and insurance
companies
• Reduction of the period related to the deduction of leasing
installments for CIT purposes
• Application of transfer pricing rules for IRAP purposes
• Extension of the scope of the International Standard ruling
• Introduction of a personal income tax (IRPEF) bonus of
€80,00 per month
2.9 Country position on OECD Base Erosion
and Prot Shifting (BEPS) Action Plan
• No public statement, consultation or legislation in relation
n Plan has been published or
enacted to date, but there is great attention paid to the BEPS
agenda from Italian tax legislators and the tax authorities. In
addition, the guidelines provided to the Revenue Agency’s
transactions listed in the BEPS Action Plan.
• The recently enacted patent box legislation includes several
Transfer pricing is another item likely to be of great interest
in Italy.
2.10 Pending tax proposals
•
framework law that enab
effective as of 27 March 2014 and provides the following
•
measurement of the tax evasion, tax erosion review)
• Measures to tackle tax avoidance (introduction of a general
investigations)
• Review of the relationship between taxpayer and tax
authority (introduction of a system of communication
and reinforced cooperation, review of the criminal and
administrative tax penalties system, review of the tax
litigation system)
•
• Introduction of rules aiming to reduce uncertainty
in determining corporate tax income (bad debts,
depreciations, amortizations, general expenses) and to
promote the internationalization of the economic agents
operating in Italy (review of the rules governing crossborder
transactions: tax residence, blacklist costs, taxation
of permanent establishments)
•
to issues a series of law decrees over the next few months.
2.11 Consultations opened/closed
• Not applicable
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