The Italian tax authorities have issued the implementing provisions of the cooperative compliance program aimed at ascertaining the existence of permanent establishments.

Large multinationals who engage in direct sales in Italy are now allowed to file a specific ruling request to determine, in an open discussion with Italian tax authorities, whether their activities amount to a permanent establishment in Italy or not.

In case a permanent establishment is determined to exist, the applicants enjoy substantial penalties reduction, avoid criminal prosecution, obtain certainty on the profit attributable to the PE and may achieve other important benefits

 

For further information on the procedure and requirements and to see on how KPMG in Italy can help please see the flyer Cooperative compliance for Italian PEs.