Prof. Guglielmo Maisto, Mailand

Following the introduction of worldwide income taxation in 1973, Italy has undertaken a robust modernization of its international tax system during the last decade and more recently achieved recognition for its shaping of anti-tax haven rules and implementation of a wide-ranging CFC regime.

A comprehensive reorganization and rejuvenation of the tax administration undertaken in 2000, an extensive tax audit practice and an effective anti-abuse doctrine developed by case law have significantly increased the level of tax compliance, enabled additional revenue and largely eliminated loopholes in cross-border transactions as well as more generally on activities conducted internationally. Although recently enacted transfer pricing legislation providing for a waiver on penalties for document-compliant multinationals has contributed to the improvement of a taxpayer-friendly tax environment, the tax authorities and the legislator must now decide on how to continue pursuing equity and compliance without impairing Italy’s tax competitiveness on inbound and outbound investment.

This lecture will address these recent trends in Italian tax legislature and tax authority practice as well as the options available to maintain an efficient and wellbalanced international tax system.