European tax for those investing in Italy




In Milan taxes as in Dublin. The idea launched by the Minister of Economy for some time with a provision inserted in the ad hoc three-year operation in July last year (Article 41), now entering the implementation phase, although experimental. The test to introduce a tax regime for financial firms will begin right from Milan. This was announced by the Minister Giulio Tremonti in his speech at the Salone del Risparmio, organized by Assogestioni (see article on pg. 44).

Tremonti has spoken of “tax shopping: If a system is good for other countries then perhaps it’s good even here in Italy.” In essence, Tremonti said, “the idea is to apply the tax in Milan, for example, that are in Ireland, for a given time and under certain conditions.”

This is a trial run open to contributions from professionals and experts. So much so that the draft decree on the tax regime to attract the EU, issued yesterday on the website of the MEF, is accompanied by a brief note specifying how the nine items represent “a draft open to any suggestions for improvement and / or change.” For those interested there is also an email address to contact for more info: As explained by the ministry it will deal with ideas or proposals that are connected with the Decree-Law 78. However, if the ideas and / or suggestions are really good, you can also consider changing the law currently in force.

As stated in the decree, the idea for persons, companies or any other entity treated as a legal resident in another EU country for at least 24 months, will be able to start a new businesses in Italy, choosing, for the sole purpose of income tax, the rules for determining the tax base and tax rates in force in one of the other EU states.

The choice of the more advantageous tax regime should be authorized by the Revenue with the presentation of an instance of questioning, the details of which shall be fixed with another decision of the Agency. However the application must be filed within 30 days from the date of transfer of residence for tax purposes or the establishment of the permanent establishment or a subsidiary or associate. This period is necessary for the tax authorities to verify the requirements for admission to a more favorable tax regime.

The new business will be started after the entry into force of the implementing decree. The scheme once approved by the Revenue will valid for up to a maximum of three tax years, beginning on the date of submission to the Revenue.



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