The article deals with the current regime for the deduction of interest in determining the business income of corporations. First of all, we examine the new formulation of the art. 96 Tuir, through which Italy has implemented art. 4 Atad. Secondly, starting from the failure to adopt the "de minimis" and "standalone" clauses by the Italian legislator, we examine the compliance of the aforementioned regime with the European principle of proportionality.
The implementation in Italy of art. 4 ATAD and the European principle of proportionality
Giuseppe Vanz
2019-01-01
Abstract
The article deals with the current regime for the deduction of interest in determining the business income of corporations. First of all, we examine the new formulation of the art. 96 Tuir, through which Italy has implemented art. 4 Atad. Secondly, starting from the failure to adopt the "de minimis" and "standalone" clauses by the Italian legislator, we examine the compliance of the aforementioned regime with the European principle of proportionality.
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