Italy: New Decree Expands The Scope Of The International Ruling Procedure

The Decree Law No. 145 of December 23, 2013 (ratified by Law No. 9 of February 21, 2014) broadens the scope of the international ruling procedure. The main area of application is transfer pricing, in particular advance pricing agreements, but it may also apply to (i) the attribution of income or losses to Italian permanent establishments of nonresident taxpayers and to foreign permanent establishments of Italian-resident taxpayers, or (ii) the application of tax treaties to dividends, interest, and royalties. Rulings issued under this procedure are binding on the taxpayer and the tax administration for the tax year in which they are issued and the following four years (two years under the regime applicable before the recent amendment).