Italy’s tax authorities released Circular No. 23/E on 19 November 2024, outlining the guidelines for the permanent establishment investment management exemption introduced in the 2023 Budget Law.
One of the key provisions in the 2024 Budget Law clarified that managing investments in Italy for nonresident investment vehicles may not establish a permanent establishment in Italy.
The tax authorities issued guidelines on permanently establishing investment management exemption, arm’s length principle application for investment manager remuneration, and necessary transfer pricing documentation.