Deducibilità dei tributi ai fini IRES e qualificazione dei rapporti giuridici retti dal diritto straniero

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.