The Italian Rule on the Deductibility of Costs Incurred in Blacklisted Countries in Light of Italian Tax Treaties: Does a Conflict Exist?

This note provides an overview of the Italian tax provisions on the deductibility of costs related to transactions involving non-resident entities located in blacklisted countries and comments upon the potential conflict of these rules with the non-discrimination provision in Italian tax treaties. The note is based on legislation, administrative practice and case law as of 23 March 2014.