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Artículos Recientes

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  06/08/2024

  Hungría

  EU Commission finetunes the Foreign Subsidies Regulation: insights into the latest Guidance

  On 26 July 2024, the European Commission released a staff working document that clarifies the Commission’s substantive test under the Foreign Subsidies Regulation (FSR). This document serves as a valuable supplementary resource to FSR case-law and provides insight into how the Commission will conduct FSR assessments. Although this document is not binding, it may also prove highly beneficial for companies in evaluating and managing FSR risks.What are FSR procedures?The preamble to the FSR states that existing EU instruments do not address distortions caused by foreign aid, prompting the Commission...

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  26/07/2024

  Italia

  Ruling no. 148/2024: tax exemption for dividends and capital gains realized by foreign funds - requirements

  The Italian Tax Authority (“ITA”), with the ruling no. 148/2024 published on July 11, 2024, confirms the application of the exemption regime - introduced by Article 1, paragraph 633, Law No. 178/2020 ("Budget Law 2021") - for Italian source dividends as well as capital gains deriving from the disposal of qualified participations realized by foreign investment funds, as better defined below.First of all, it should be recalled that the aforementioned Budget Law 2021 introduced the exemption regime for Italian-source income, consisting of dividends and capital gains (or capital losses)...

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  21/06/2024

  Italy

  Italian Supreme Court Upholds OECD Transfer Pricing Rules

  The decisions of the Italian Supreme Court nos. 10577/2024 and 10499/2024 (concerning the same case for corporate income tax and regional income tax purposes) confirm important principles regarding transfer pricing transactions between associated companies.Firstly, the approach taken in the previous decision of the Italian Supreme Court no. 15668/2022 (available here) is confirmed with regard to the relevance of the arm’s length principle set forth by Article 9 of the OECD Model Tax Convention and included in Article 110, par. 7 of the Italian Income Tax Code.Moreover, the principle that,...

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  22/05/2024

  Italy

  Digital nomad tax insights

  The new visa for digital nomads might become a particularly interesting option for workers who may benefit from the so called “impatriate” tax regime following their relocation to Italy. The Decree of February 29, 2024, in force since April 5th, has established the entry and residence permit issuance procedures for "digital nomads" and "remote workers".The provisions apply to non-EU citizens who perform highly skilled work using technological tools that allow remote work; more specifically this definition refers to self-employed foreign workers (digital nomads) or foreign employees...

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  14/05/2024

  Hungría

  EU introduces criminal offences and penalties for sanctions violations

  Criminal offencesUnder the Directive, the following conduct constitutes a criminal offence when committed intentionally and in violation of restrictive measures or a national provision implementing restrictive measures:making funds or economic resources available directly or indirectly to, or for the benefit of, a designated person, entity or body;failing to freeze funds or economic resources belonging to or owned, held or controlled by a designated person, entity or body;enabling designated natural persons to enter into, or transit through, the territory of a EU member state;entering into or continuing...

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  13/05/2024

  Hungría

  UK's Accession to the 2019 Hague Convention to ensure enforcement of UK court judgments

  In January 2024, the UK acceded to the 2019 Hague Convention, which unequivocally permits the enforcement of UK court judgments, regardless of whether a jurisdiction clause is exclusive/symmetrical.The UK’s accession to the 2019 Hague Convention brings clarity and certainty regarding certain types of jurisdiction clauses and the enforcement of UK court judgments in other countries in the aftermath of the UK’s departure from the EU in 2020.As a reminder, prior to BREXIT on 31 December 2020, the UK through its EU membership was party to the Lugano Convention, which facilitated the enforcement...

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