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Tax authorities reverse position on VAT treatment of branch transactions

Italy’s tax authorities issued a ruling that provides updated guidance on the VAT treatment of the provision of services between two permanent establishments of the same entity (a German company in the case at hand), where one PE is established in Italy and the other is located in the UK, where the latter belongs to a UK VAT group. Departing from its previous position (in Ruling No. 756/2021), the tax authorities determined that such transactions are outside the scope of Italian VAT and thus irrelevant for VAT purposes in Italy.

Source: BDO

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