The author, in this article, discusses Article 14 of Legislative Decree no. 147/2015 ("Internationalization Decree"), through which Italy allows taxpayers to opt for a branch exemption in respect of the profits and losses of a foreign... more
The author, in this article, discusses Article 14 of Legislative Decree no. 147/2015 ("Internationalization Decree"), through which Italy allows taxpayers to opt for a branch exemption in respect of the profits and losses of a foreign permanent establishment as an exception to the credit method.