The case has corporate income tax, VAT and registration tax implications
The contribution of the entire
business of an EU company’s Italian permanent establishment (PE) to another EU
company’s Italian PE is tax neutral under section 176 of Italian Tax Code
(TUIR). This is the conclusion reached by the Central Revenue, as an answer to the
request for advance ruling No. 633 as of December 31 2020.
Circumstances of the case
The case concerned an EU company
(hereinafter ALFA) which intended to transfer its PE in Italy (hereinafter ALFA
Italy PE) to the BETA company resident in another country of the EU, against of