Newsletter | Tax 21/11/2024

On 19 November 2024, the Italian Revenue Agency released Circular letter no. 23/E on the application of the so-called Investment Management Exemption (“IME”).

The Circular Letter addresses relevant issues such as the effectiveness of the IME and its scope of application, independence requirements for non-EU collective investment undertakings (‘CIUs’) and for other non-EU entities, the application of the IME to Master/Feeder structures and to cases of delegation or sub-delegation of asset management activities, as well as the transfer pricing aspects for intra-group transactions.

Chiomenti Professionals analysed the details of the Circular Letter in the latest newsletter.