On 7 April 2016, the Italian Tax Authorities (ITA) issued Circular No. 11/E providing new clarifications on the patent box regime introduced by Law No. 190 of 23 December 2014, i.e. the Stability Law 2015.
In the Circular, ITA provide specific clarifications and guidance with respect to, inter alia, the exercise of the option for the application of the regime and the related tax ruling procedure, the definition of qualifying R&D activities and qualifying IPs, also taking into account the recent amendments introduced by Law No. 208 of 28 December 2015, i.e. the Stability Law for 2016, the calculation of qualifying income and applicable methods, and the nexus ratio.
Further details will be reported in due course.