The Investment Management Exemption Regime

Fourteen months after the Italian Government’s amendment to art. 162 of the Italian Corporate Tax Code (ICTC), introducing new § 7-ter, 7- quarter and 9-bis, the Revenue Agency Ruling No 68668/2024 (the Ruling) and the Ministry of Economy and Finance Decree released on February the 22nd 2024 (the Decree) provided therules for implementing the s.c. investment management exemption.

Under such regime, the asset manager performing support and ancillary services from the Italian territory to an investment fund resident abroad is deemed not to be a dependent agent and therefore not to trigger the condition to be qualified as a permanent establishment in Italy.
Here below is a quick recap of the rules introduced by the Italian administration.

  • Marco Pistis
    Corporate Law in Italy

    Marco Pistis

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