The paper covers the corporate tax regime regarding the deductibility of foreign taxes with special reference to Article 99 of the Consolidated Tax Act which stipulates the non deductibility of income taxes with no mention on foreign taxes. The issue of the deduction of foreign taxes which are similar to Italian taxes for which non deductibility is expressly provided is also covered. On the basis of the interpretative issues raised by current legislation, legislative changes are also proposed to the provisions governing corporation tax.
|Translated title of the contribution||[Autom. eng. transl.] Deductibility of taxes for IRES purposes and qualification of legal relationships governed by foreign law|
|Number of pages||19|
|Journal||RIVISTA DI DIRITTO TRIBUTARIO|
|Publication status||Published - 2013|