Italy Issues Rules on Foreign Permanent Establishment Exemption

On 28 August 2017, the Italian Revenue Agency issues Protocol No. 2017/165138, which provides rules for the exemption of profits and losses of foreign permanent establishments (branches) of Italian resident companies as introduced in Legislative Decree No. 147 in September 2015 ({News-2015-09-30/A/2-previous coverage}). Some of the main points of rules include:

• The election to exempt profits and losses of a foreign branch is made in the tax return for the first tax period in which the branch…