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Italy: Patent box regime, other corporate income tax measures

Italy: Patent box regime, corporate income tax measures

A law decree that amends the patent box regime and that provides other corporate tax measures was “converted into law” on 15 June 2017.


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The new law decree (no. 50 of 24 April 2017) removes trademarks from the list of qualifying intangibles under the patent box regime. The limits on the patent box regime apply to taxpayers that elect to apply the patent box regime after 2016 (for calendar year taxpayers, the patent box benefits are no longer available for income attributable to trademarks from 2017). “Grandfathered” measures apply for elections with respect to trademarks in tax years in progress as of 31 December 2016.

Other provisions in Law Decree no. 50 include:

  • Reduced rates for the allowance for corporate equity (which may be deducted from a company's net taxable income)
  • A measure replacing the concept of fair market value with an arm's length concept for transfer pricing purposes
  • A ruling procedure whereby multinational entities can apply to the Italian tax agency for a ruling as to whether their business activity constitutes a permanent establishment


Read a June 2017 report [PDF 183 KB] prepared by the KPMG member firm in Italy

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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