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Italy Tax Agency Clarifies Taxation of Nonresident PE of U.K. Company Post-Brexit

May 13, 2022, 5:00 AM

The Italian Revenue Agency May 10 issued Letter No. 251/2022, clarifying the capital gains taxation between Italian and U.K. companies post-Brexit. A U.K.-based banking company qualified as a PE in Italy. The taxpayer requested clarification as to the taxation of a branch transfer post-Brexit. The tax agency clarified that: 1) the shares issued by the company are recorded in the assets of the Italian branch; 2) the tax neutrality regime applies to the capital gains; 3) the company ceased its residential status; and 4) the taxation should be derived from the respective DTAs. [Italy, Revenue Agency, 05/10/22]

Reference:
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