The New Definition of Financial Intermediaries under Italian Tax Law Following the Implementation of the Anti-Tax Avoidance Directives

In this article, the author scrutinizes the new definition of “financial intermediaries” adopted for Italian tax purposes against the background of recent EU and international initiatives that deal with the exclusion of financial entities from general interest limitation rules, namely Action 4 of the BEPS Project and article 4 of ATAD 1. In doing so, the author highlights that the perspective adopted under Italian tax law could give rise to EU law issues.