Involvement by fixed establishment in Italy even if contracts are not negotiated

• The Italian Tax Agency, in response to an inquiry, analyzed the relevance of various operations carried out by a Dutch company’s permanent establishment in Italy. The establishment is part of a Brazilian automotive group.
• The Italian establishment, although not directly involved in contract negotiation, would engage in complex activities with the involvement of seven employees.
• The Tax Agency recognized that the Italian employees’ activities significantly influence the non-resident company’s business in Italy, qualifying the establishment as a taxpayer for operations conducted in Italy.

Source: eutekne.info

See also Ruling 374: Involvement of an Italian branch

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