Transfer of business branch: when is it territorially relevant for VAT purposes?

• The Italian tax agency, Agenzia delle Entrate, has clarified the application of the registration tax for the transfer of a business branch.
• The registration tax is applied proportionally based on the nature of the assets that make up the business, as long as separate consideration is identified.
• The agency considers a business as a complex entity of assets, relationships, and rights, and the territoriality of its transfer for VAT purposes cannot be governed by provisions related to service provision.
• This is because the business branch is primarily composed of intangible assets.
• The clarification was provided in response to an inquiry from September 28, 2023.

Source: ipsoa.it

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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