20230120

The Budget Law 2023 arrives in Italy: new tax innovations introduced

Italy is changing in the tax area and adopting new measures. The Finance Act 2023, which came into force on 1 January following its publication in the Official Gazette on 29 December 2022, introduces important changes in tax matters that closely affect companies operating in various countries around the world, including Italy.

The new provisions draw attention to various issues of primary importance in the tax sphere: the provisions concerning the definition of permanent establishment the tax treatment of certain incoming dividends; the introduction of rules concerning the taxability of certain capital gains from the sale of shareholdings in companies whose value derives mainly from Italian real estate (the so-called “Land-rich rules”); the definition of certain assessment procedures by the Agenzia delle Entrate a significant reduction in administrative penalties for taxpayers who voluntarily correct tax violations of undeclared or unpaid money; the definition of the provisional solidarity contribution for 2023 that applies to the surplus profits of Italian entities operating in certain sectors, modifying the calculation of the solidarity contribution for 2022 (which could require certain entities to pay an additional tax for 2022).

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