Changes in the Internationalization Decree Regarding PEs of Non-Resident Entities and Possible Implications on Source Taxation of “Notional Income”

This note discusses the changes included in Legislative Decree 147/2015 regarding measures for the growth and internationalization of enterprises. In particular, the focus is on article 7, which has changed the regulation of Italian PEs of non-resident entities by revising the principles for the determination of the tax base of non-resident taxpayers. Furthermore, the contribution addresses some tax issues, in terms of source-country taxation, regarding internal dealings between Italian PEs and parent companies.