Tax and Revenue Law

Limited Liability Companies: Directors’ Liabilities

The Italian Corte di Cassazione has determined that a Director – even not empowered – has to be considered responsible for the Company’s illegal or irregular action he did not actively prevent the contra legem event.

New Tax Regimens in Chile

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The tax reform approved from January 2017 is a game changer. There will be two alternative income tax regimes for companies. The following is a brief explanation of each regime included in the reform.

After Mortgage Floor Clauses and Mortgage Expenses ... Now Comes the Increase in the Value of Urban Land

The constitutionality of the Tax on the Increase of the Value of Urban Land has been called into question for several years now. Many of these lawsuits will depend on the decision of the Constitutional Court.

Any Tax Assessment Must Be Compulsorily Preceded by a Preliminary Hearing with Taxpayers!

The question and the related discussion on the subjected matter arose nine years ago, right after a ruling delivered by the European Court of Justice. A significant contribute on the path of justice and fairness between citizens and Administration.

Analysis of the New Tax on Non-Productive Assets of Legal Persons

Recently, the group "Juntos por el Sí" and "CUP" have presented to the Catalan Parliament a proposal for a Law on the new "Tax on the non-productive assets of legal entities" which the Parliamentary Bureau has admitted to processing.

Cross-Border Successions

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The growing phenomenon of migrations of citizens in and out the EU’s borders has brought as a consequence some significant issues about cross-border successions.

Comments on the New System for the Immediate Supply of VAT Information (SII)

On July 1, 2017, the Immediate Information Delivery System (SII) will enter into force. This basically consists of the electronic sending of information relating to invoices issued and invoices received.

Voluntary Disclosure 2.0: Last Call for Latecomers!

The Italian Voluntary Disclosure (also named VD or Collaborazione Volontaria) is a temporary fiscal Institution that allows those who illegally hold assets in Italy or abroad (cash, investments, real estate, boats, precious and so on) to regularize any lawlessness. In other words, VD enables collaborative taxpayers interested to emerge from illegality to confess – spontaneously – to the Italian Internal Revenue Service (Agenzia delle Entrate) their own lacks regarding both tax legislation and anti-money laundering rules.

Special Tax Regime on Foreign Income for New Residents in Italy

A special tax regime has just been introduced in Italy, effective from January 1, 2017, in favor of high net worth individuals who decide to move to Italy. The new resident will be entitled to ask for the application of the ordinary tax regime.

The Mandatory Reversal of Portfolio Impairment Losses and Possible Solutions

It was also regulated by a transitional provision when the reversion should occur: basically and simplifying, when the value of equity of the investee at year-end exceeded the value of equity at the beginning. With RDL 3/2016, a new reversal was introduced, which in essence constitutes a minimum annual reversal amount.