Can a permanent establishment be a "legitimate heir" in a domestic consolidated tax regime?

Journal
Adda, M.
Italy
European Taxation 2008 (Volume 48), No. 5
FormatPDF
EUR
40
| USD
45
(VAT excl.)

A recent ruling issued by the Italian tax authorities presents an opportunity to verify if, with regard to a particular issue concerning the contribution of a permanent establishment (PE), there is still sufficient ground of justification to distinguish between a dependent entity (a PE) and an independent entity (a subsidiary) in the context of group tax regimes.