Amendments to transfer pricing and patent box regime in Italy, proposed reduction of CIT in Greece

BEPS news

Italy - New Corporate Tax Measures
Law Decree No. 50 of 24 April 2017 will amend the existing patent box regime in order to comply with the recommendations of BEPS Action 5. The main change will be to exclude trademarks from qualifying IP assets that can benefit from deduction of corporate income tax. Taxpayers already enrolled into the previous patent box regime can benefit from it until 30 June 2021 under the grandfathering period. 

​OECD - BEPS Action 13: OECD Releases CbCr Implementation Status
On 4 May 2017, the OECD released the full list of automatic exchange information between 57 jurisdictions participating in exchange of country-by-country (CbC) reporting. The list of all participants can be found at:

http://www.oecd.org/tax/beps/country-by-country-exchange-relationships.htm

Additionally, information about "surrogate filing" and “voluntary surrogate filing” can also be found under the relevant document on OECD website.

Local tax news

​Greece - Draft Bill Amendment Income Tax Code
On 17 May 2017, the amendments to Greek Income Tax Code were proposed. If the budgetary objectives and fiscal targets towards creditors will be met, the corporate income tax (CIT) rate will be reduced from 29% to 26% from 1 January 2019 and not from 1 January 2020 as previously reported.

The assessment whether the budgetary objectives and targets are met will be jointly examined by the International Monetary Fund (IMF), the European Commission (EC), the European Stability Mechanism (ESM) and the Greek authorities.

Italy - New Corporate Tax Measures
Law Decree No. 50 of 24 April 2017 amends transfer pricing legislation which made reference to the concept of "normal value" which does not always correspond to the arm's length criterion. Under the amended legislation a formal reference is made to arm's length as defined by OECD Guidelines. Amended article 110(7) refers to “conditions and prices which would have been agreed between independent persons operating on an arm's length basis and in comparable circumstances”.
​
Russia - Tax Incentive for Corporate Investments - Proposed
In order to stimulate the economy and investment in high-tech industry, the government proposed the introduction of a corporate tax incentive that would reduce the corporate tax rate from 20% to 5%. The incentive will be available to companies investing their profits in long-term assets, for example, advanced technology machinery.

If these subjects are something which you find interesting and would like to discuss further we are happy to be at your service. Contact us at [email protected].