On 20 November 2020, the Italian Government published an updated version of the draft budget law for the year 2021, which is currently under discussion within the Italian Parliament. Following tax measures contained in the Draft Budget relate to:
- Extension of the tax deduction regime for qualifying works to financial year (FY) 2021
- Extension of Advance Pricing Agreements (APAs) rollback
- Tax benefits for selected business aggregations
- Withholding tax exemption on dividends and capital gains for EU/EEA investment funds
The draft Budget 2021 introduces an exemption from the Italian withholding tax on dividends and capital gains for selected EU/EEA investment funds. If the Draft is approved, the new exemptions for EU/EEA funds should be applicable to dividends paid and capital gains realized from 1 January 2021 onward.
For filing an APA ruling request before the Italian tax authorities, the enterprise shall pay a fee equal to:
- €10k where the overall turnover of the group is lower than €100m;
- €30k where the overall turnover of the group is higher than €100m and lower than €750m; and
- €50k where the overall turnover of the group is higher than €750m.
