The title is certainly effect and does not want to be an invitation to daring operations at the edge of the abuse of rights, of which each would assume responsibilities; the goal is to report as the location that the Agency has recently taken in the circular 10/April 4, 2016 and, in terms of taxation of capital gains under the flat rate system, has a flaw that threatens to subtract taxable...
Read MoreThe rules in force concerning liability of the recipient companies of a split for tax liabilities relating to the company being divided appears very unclear and mainly presents the real risk of penalising unjustifiably the legitimate protection of the interests of the beneficiaries themselves. In fact, article 173, paragraph 13, of the tax code, raises the offices of financial administration...
Read MoreIn determining the limit of deduction of tax paid abroad a matter to be addressed is that of the possible effects of the application of the patent box. The issue is particularly important especially for companies (and businesses in General) which license out to foreign entities be subsidized intangibles (patents, software, trademarks, know-how, etc.), to portray the fees (usually royalties)...
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