Europe: Italian tax changes in relation to Italian banking arrangements

International industrial and manufacturing businesses that have Italian businesses or subsidiaries that have banking facilities in Italy should be aware of recent Italian tax changes, which apply to medium- or long-term loans executed in Italy and granted by a bank or financial institution in Italy (loans longer than 18 months are considered medium- and long-term loans).

The previous rule provided for the mandatory application of the substitutive tax, which applied a tax rate of 0.25 per cent on the amount of the loan, instead of the application of registration tax, stamp duty, mortgage and cadastral tax and franchise tax.

The new rules specify that borrowers now have the possibility to choose which taxation regime should be applied to the loan. That decision must be made in writing in the relevant loan agreement or banking documentation…

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