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News, Transactions

The Firm assists one of the largest Italian airport management companies with a ruling on the deductibility of VAT on expenses incurred on third party assets

11 February 2021
Tremonti Romagnoli Piccardi e Associati successfully assisted one of the largest European players operating in the transport infrastructure management sector in a ruling on the deductibility of VAT paid on expenses relating to non-owned assets that were not used in carrying out the business activities, but whose incurrence was expressly provided for by the sector regulations. Read More

Litigation, News

Supreme Court victory for the Firm on behalf of Domina in relation to permanent establishment

5 February 2021
The Supreme Court upheld the appeal of Domina, duly assisted by the Firm, regarding the criteria for determination of the income of an Italian permanent establishment of the Egyptian company belonging to the group, active in developing tourist properties. The Supreme Justices, adhering to the constitutionally oriented interpretation proposed by the defence team, stated that, also in relation to permanent establishments, the reconstruction of the taxable income must be carried out net of all production costs, allowing a reconstruction that is also inductive/presumptive. Read More

News, Training and Events

The Firm submits its comments to the Italian Tax Authority’s public consultation on the draft circular letter regarding implementation of the DAC 6 Directive

18 January 2021
Tremonti Romagnoli Piccardi e Associati submitted its comments to the Italian Tax Authority as part of the public consultation concerning the draft of the circular letter aimed at providing clarification on the topic of cross-border mechanisms subject to the communication obligation – Legislative Decree of 30 July 2020, no. 100 (implementation of the “DAC 6” Directive). Read More

News, Transactions

The Firm advises Credit Agricole Group on Patent Box agreements

6 January 2021
The Firm advised the Italian banks and financial companies of the Credit Agricole Group (specifically, Credit Agricole Italia, Credit Agricole Friuladria, Carispezia and Agos) in the procedure culminating in the signing, with the Revenue Agency, of the agreements concerning the preferential taxation regime provided for by the so-called Patent Box legislation for income deriving from the direct use of trademarks. Read More

Litigation, News

The Firm with CREDEM before the Constitutional Court regarding IRAP taxation on bank dividends

22 December 2020
As part of a refund proceeding brought before the Provincial Tax Court of Reggio Emilia on behalf of the CREDEM group, the Firm obtained the referral to the Constitutional Court of the question of constitutionality of art. 6, first paragraph, letter a), Legislative Decree no. 446/97, in relation to the section which provides for the “flat rate” taxation for IRAP (Italian Regional Tax on Productive Activities ) purposes of 50 per cent of all dividends received by banks rather than the analytical taxation of trading dividends only, in violation of the principle of proportionality pursuant to art. 3, Constitution. Read More

News, Training and Events

Tax Alert – OECD Guidance on the transfer pricing implications of the COVID-19 pandemic

21 December 2020

Tax Alert – December 21, 2020

                         OECD Guidance on the transfer pricing implications of the COVID-19 pandemic

 Introduction and summary.

On December 18, 2020 the OECD published the awaited “Guidance on the transfer pricing implications of the Covid-19 pandemic” (hereinafter, the “Guidance”) detailing the main tools for taxpayers and tax administrations in order to deal with the transfer pricing rules for periods impacted by the COVID-19 pandemic. Read More

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