Italian tax changes: implications for medium- and long-term banking arrangements

International retail businesses that have businesses or subsidiaries with banking facilities in Italy should be aware of recent tax changes within the country. The changes apply to medium- or long-term loans executed 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 consisted of a mandatory application of the substitutive tax. The substitutive tax applied a tax rate of 0.25 per cent on the amount of the loan, instead of applying registration tax, stamp duty, mortgage and cadastral tax and franchise tax.

The new rules now allow borrowers to choose which taxation regime should be applied to the loan, and the decision must be made in writing in the relevant loan agreement or banking documentation…

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