Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions with “black list” jurisdictions are allowed up to an “arm’s length” value. Amounts above that value may be allowed if the taxpayer can establish the genuine business reason for the transaction and the manner in which it was conducted. The advance ruling procedure applies for investments not less than €30 million as per the Legislative decree. The Legislative decree also allows for five years binding agreements with the tax authorities.
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