14 September 2016 Italian Tax Authorities clarify company migration to Italy The Italian Tax Authorities (ITA) recently provided guidance on the new rule on the transfer of tax residency to Italy (so called "inbound migration") with Resolution no. 69/E/2016 (the Resolution). The inbound migration rule applies to "commercial" companies migrating from a white list jurisdiction to Italy and allows them to step up, from a tax perspective, their assets and liabilities at fair market value, irrespective of any exit taxation applied in the country of origin. The Resolution analyzes a cross-border merger between an Italian tax resident and a nonresident real estate holding, which would consequently lose the tax residency in Luxembourg. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1544 |
