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Italy - New Rules on the Attribution of Profits to Permanent Establishments (70 Bulletin for International Taxation 6, 2016)
Abstract
In this article, the author examines both the former and new rules for the computation of income attributable to Italian permanent establishments and analyses the qualification of business income of non-resident enterprises under Italian tax law. Further, the recently enacted branch exemption regime, pursuant to which resident enterprises may opt for an exemption in respect of the profits of foreign PEs from the Italian tax base, is discussed.
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