Limits and Ambiguities of Article 162, Paragraph 2, Letter f-bis) of the TUIR

• The Italian legislator updated the concept of permanent establishment with the 2018 budget law.
• This update introduced a new provision in the TUIR regarding significant and continuous economic presence.
• The provision aims to address digital economy taxation without requiring physical presence.
• Years after its implementation, the provision still raises questions about its effectiveness.
• There is debate on whether it establishes a new type of permanent establishment.

Source: eutekne.info

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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