Recently, Italy issued a new law decree introducing significant amendments in relation to international tax matters. The measures mark a significant shift in Italy’s international tax policy, establishing for the first time a special tax regime aimed at encouraging the reshoring of economic activities. Thomas Pichler provides a comprehensive summary of the critical aspects of this new tax legislation. These include the precise definition and scope of “relocated economic activities", the potential complexities in applying the new rules to different types of economic entities, and the alignment with existing international tax agreements and standards. Furthermore, the author points out the need for detailed guidance from the Italian tax authorities to navigate these changes effectively, emphasizing the challenges in implementing a practical approach for an appropriate profit allocation to the relocated entity. In conclusion, the implications of these regulations on Italy’s position in the global economic landscape are examined, considering both the opportunities and the potential pitfalls.
