An analysis by LED Taxand
The 2023 Italian Budget introduced the investment management exemption, a provision according to which the investment management activities carried out in Italy by asset managers do not give rise to a permanent establishment of the foreign investment vehicle (or its subsidiaries) if certain conditions are met.
As such, an Italian or foreign tax resident asset/investment manager operating in Italy, which habitually concludes (or contributes to the conclusion of) contracts for purchasing, selling or negotiating financial instruments (including derivatives, shares and receivables) in the name and/or on behalf of the foreign investment vehicle (or its subsidiaries), does not constitute a PE under certain conditions.
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