Tax Pills

Italian housing market: +3.8% in the second quarter 2017
From April to June 2017, Italian real estate market continues to expand, even if with a slower pace. The housing market has increased by 3.8%, namely about 5,000 houses sold over the same period in 2016, while cellars and attics sales has grown by 10.1%. A positive trend has also affected the non-residential market: in particular, offices and retail sector has increased by 6.2% and the industrial one by 4.9%. Among the main cities, good achievement for Napoli, Palermo e Torino, except for Bologna, the only one showing a decrease. These are the main data emerging from the Real Estate Market Observatory (OMI) of the Italian Revenue Agency- Agenzia delle Entrate - inside the Quarterly report published today on its official website. Data used in the report are retrieved from different archives: the cadastral database, the land registry and the Real Estate Market Observatory, all managed by Agenzia delle Entrate. The cadastral database provides information about cadastral typologies, the land registry gives the number of real estate units sold and the Real Estate Market Observatory database provides information about real estate value. Data cover the whole national territory, excluding four areas (Bolzano, Trento, Gorizia, and Trieste) where the cadaster and/or the land registry are managed by local administrations. Real estate units are grouped by use (house, appurtenance, office, retail and industrial) according to the cadastral categories provided in the deeds of transfer.
About the housing market report - In the residential market report, the Real Estate Market Observatory notes a slower growth, although the housing market continues on the uphill trail that has characterized the last 3 years. Between April and June were sold 145,529 houses and 16,400 cellars and attics. Housing market was more dynamic in the Southern area of Italy (+5%) while the lowest value was recorded in Sicilia and Sardegna (+0.9%). Anyway, islands market weighs less than a tenth of the national total sales. The average floor area of the house purchased is 105 square meters, in line with last year’s values. The cellars and attics market has increased about 10%, more in the northern area than in the rest of Italy, where sales leap forward of about 20%. The average area of an appurtenance is 14 square meters, slightly lower compared with the previous quarter of the year.
The main cities - Regarding the main Italian cities, the highest growth rate was represented by Napoli (+13.6%), with 2,082 transactions, followed by Palermo (+8.3%) and Torino (+5.7%). Rome and Milan aligned with the average of other Italian metropolises, rising more than 4% (+4.5% and +4.1% respectively). The housing market in Genova (+1.3%) and Firenze (+0.9%) appears less dynamic, while Bologna was the only big city with a decrease (-4.3%), resulted in about 1.500 transactions in the second quarter of 2017.
The non-residential market - Compared to the same quarter of 2016, the offices and shops market grows by 6.2%. The highest increases have been registered in the North West (with a growth of 10.9%), followed by Sicilia and Sardegna, where the number of sales and purchases rises of 7.6%.
In the same period, warehouses and industries market marks a 4.9% increase: despite of the modest growth, the data for the second quarter of 2017 are close to the levels that preceded the collapse of 2012. This increase is supported by the growth of transactions in the center and in the north west areas (+18.7% and +11.3% respectively), while the sales in the other areas have been more moderate, except for the two main islands, where the Observatory has registered a heavy decline (-37.3%). The residential and non-residential reports, with more detailed information, graphics and data references, are available in Italian on the website

Italy's branch exemption new scheme ready| to meet next year corporate income taxes
immagine generica illustrativa
New rules apply only to real permanent organizations, while Oecd criteria will guide the calculation of significant foreign profits and losses.
Everything is ready for the start of the new branch exemption scheme sized for Italian companies with a permanent overseas organization. On 28 August 2017, in fact, the Italian Revenue Agency published an ad hoc Statement of Practice, or Provvedimento del Direttore dell'Agenzia delle Entrate, on its website containing further clarifications aimed at implementing the new fiscal regime. Particularly, the Statement has defined modalities and criteria to follow for the correct implementation of the scheme companies can opt for, envisaging the exemption of income and eventual losses arising from their permanent organizations, as provided by Article 168-ter of the Italian Income Tax Code - IITC.
What is the branch exemption and what it does for businesses - The Legislative Decree n. 147/2016, aimed at encouraging the growth and internationalization of companies, introduced the "Branch Exemption" fiscal regime to align the Italian tax system with that of other developed countries. In short, under the new Article 168-ter of the Italian Income Tax Code, as of 2016, resident enterprises may opt for an exemption regime for the profit and losses of their foreign permanent establishments, Pes, as an alternative to ordinary taxation with tax credits.
The option fiscal calendar - The regime can be opted for in the yearly tax return related to the opening period of the foreign affiliate, whilst for the branches already on track before 31 December 2016, the option can be finalized the 2018 tax return, with effect ranging from the 2017 tax period. Particularly, is important to remember that the option must be exercised for all the foreign Pes of the resident company according to the principle "all or nothing". However, opting for the regime for the PE that was established first automatically binds any other PE established later, without the need to opt for the regime for each.
Determination of the income exempted - The income of an exempt PE is determined based on the profits and losses attributable to the PE itself in accordance with the provisions of the Double Tax Treaty in force between Italy and the state in which the PE is established. Even in the absence of a DTT, profits and losses are attributed and the endowment fund is determined in accordance with Oecd criteria and technical principles. Therefore, the PE must be viewed as a separate entity, carrying out the same or similar activity under the same or similar conditions, taking into account results obtained, risks assumed and assets used. As a result, profits and losses arising from exempt foreign branches are not included in the resident company's taxable income.
Tax ruling - The Revenue Statement confirms the possibility to obtain a binding ruling from the Italian Revenue Agency on the existence of a PE of a resident company abroad. Such a ruling will be based on the information and documents submitted by the company itself in the standard ruling request.

FiscoOggi è una pubblicazione dell'Agenzia delle Entrate - Ufficio Comunicazione
Testata registrata al Tribunale di Roma il 19.9.2001 con n. 405/2001
Direttore responsabile Claudio Borgnino