...
NEWS

Permanent Establishment: how the OECD intervened

Focus concentrated on the avoidance of the status (art.12-15), exemptions for specific activities and the anti-fragmentation rule.
Share:

Table of Contents

The Beps project

The Base erosion & profit shifting (Beps), created by the OECD, is a project born with the aim to build an integrated fiscal system between the States, promoting common measures, and trying to remove fiscal avoidances, with the tool of the multilateral convention. The single state will then approve the convention with a confirmation law, introducing the new Beps measures in the country’s system. Regarding the permanent establishment, the focus was concentrated on the avoidance of the status (art.12-15), exemptions for specific activities and the anti-fragmentation rule.

The main problem with this method is its flexibility, since every state can decide not to apply certain aspects of the treaty, creating uncertainty on the width of the application of these measures, although some minimum standards were set. The multilateral convention was implemented from 1st July 2018, with 65 countries that already confirmed their acceptance.

Consultation on Permanent establishment in Italy

Regulatory Framework

Authority Source Number Article Type Date Link
A&P related service:

Analysis Permanent Establishment in Italy and Abroad

Guide to permanent establishments in Italy: definition, what constitutes a permanent establishment, taxation in Italy.

Contact us for this service

336

Complete the form to get a response from our experts

Related Insights

Income Tax Law
What is an innovative startup? An overview of legislation, regulation and benefts....
Income Tax Law
Guide on how to start a sole proprietorship for artisans and traders, including advantages and disadvantages of the business form....
Income Tax Law
Pursuant to Italian Legislative Decree n. 231, dated 8 June 2001....
Loading...

Related News

Income Tax Law
The Italian Revenue Agency further clarifies the compliance of withholding agents for a foreign non-resident entity....
Income Tax Law
With a legislative decree preliminarily approved on March 13, 2025, the Italian Government introduces changes to the Biennial "Concordato Preventivo": exclusion of flat-rate taxpayers, a new deadline of September 30,...
Income Tax Law
The Italian Revenue Agency has clarified the withholding tax regime applicable to the fees received by a Spanish company for services provided to an Italian client....

More related Services