Ruling 318/2022: Transfer of functions and personnel intercurrent between parent and permanent establishment, as well as between two permanent establishments

The Revenue Agency affirms the VAT irrelevance of the transfer of functions and personnel carried out by the foreign parent company and its permanent establishment in a different foreign country in favor of an Italian permanent establishment, if the operation, however structured, does not determine any legal succession in existing contracts with customers and suppliers and
actually results in the renegotiation of employment contracts at the new headquarters according to Italian law, subject to termination of employment contracts at the original seat.

Sources:

• gov.it
• eutekne.info

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