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Structuring permanent establishments and tax treaties with certainty

A permanent establishment or subsidiary gives rise to immediate compliance obligations that take many companies by surprise. The tax qualification has far-reaching consequences for registration obligations, profit attribution and the tax burden. For international groups, we analyse these risks at an early stage and create clear bases for decision-making.

Monitoring economic developments and relevant industry trends Monitoring economic developments and relevant industry trends

Avoiding double taxation, gaining planning certainty

Tax treaties between Italy and other countries offer considerable structuring potential – provided they are applied correctly. We advise on treaty application, on the tax planning of inbound and outbound structures and on the attribution of profits between head office and permanent establishment. In doing so, we take into account Italian tax law as well as the generally recognised OECD principles and the applicable EU provisions.

Well-organised files and documents with a view of Merano’s old town Well-organised files and documents with a view of Merano’s old town

Agency and construction site permanent establishments, tax registration obligations in Italy or the distinction between subsidiary and permanent establishment require careful tax planning. The focus lies on legally secure structuring and the consistent attribution of profits and income in an international corporate context.

Your contacts

Dott. Comm. Josef Vieider Dott. Comm. Josef Vieider Dott. Comm. Josef Vieider Email: [email protected] Phone: +39 0471 288 333 View profile →
Dott. Comm. Alessandro Zanellato Dott. Comm. Alessandro Zanellato Dott. Comm. Alessandro Zanellato Email: [email protected] Phone: +39 0471 288 333 View profile →
Dott. Comm. Stefan Lanznaster Dott. Comm. Stefan Lanznaster Dott. Comm. Stefan Lanznaster Email: [email protected] Phone: +39 0471 288 333 View profile →
Dott. Comm. Thomas Pichler Dott. Comm. Thomas Pichler Dott. Comm. Thomas Pichler Email: [email protected] Phone: +39 0471 288 333 View profile →
Dott. Comm. Sabrina Tabiadon Dott. Comm. Sabrina Tabiadon Dott. Comm. Sabrina Tabiadon Email: [email protected] Phone: +39 0471 288 333 View profile →
Newsletter

Our newsletters – Useful Updates on Tax and Legal Matters

22.09.2026, Newsletter no. 38/2026

Periodic reporting by delegated directors – reminder for the first half of 2026

Delegated directors must report to the board of directors and the statutory auditors at least every six months on business performance, outlook and major transactions. The documentation for the first half of 2026 should be completed within the third quarter.

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02.09.2026, Newsletter No. 36/2026

Refund of foreign VAT – applications for 2025 to be filed by Wednesday, 30 September 2026

Companies and self-employed professionals may claim a refund of VAT paid in other EU Member States during 2025 up to 30 September 2026. We summarise the procedure, deadlines, minimum amounts and documentation requirements.

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