30 Dec

Giuliano Foglia discusses the possibility of identifying the parent company as an intermediary for the purposes of DAC6 regulation

In today’s edition of ‘IlSole24Ore’, Giuliano Foglia comments on a number of relevant aspects of the DAC6 framework, relating to (i) the possible qualification of parent companies as “intermediaries” and (ii) the exemption regime under Article 3(3) of Legislative Decree no. 100/2020. This is also in light of the clarifications contained in the draft...
14 Dec

Claudio Grisanti and Lucia Sanseverino comment on conventional salaries without an anti-Covid ‘shield’

The potential consequences, in the absence of an official interpretation by the Tax Authorities, of the employment restrictions due to the Covid-19 emergency on the application of income taxation based on the “conventional values” provided for by Article 51, paragraph 8-bis, of the TUIR for workers with tax residence in Italy who work abroad. The...
08 Dec

Duccio Casciani and Francesco Capogrossi discuss the uncertain incompatibility between the allowance for late payment and the penalty for late payment of excise duties

The Supreme Court of Cassation, in its interlocutory order no. 12762/2020, requested the Office of the Supreme Court to report on the incompatibility between a penalty for failure to pay or delay in paying excise duties and a penalty for late payment.  The need for the enquiry stems from the presence of two opposing...