This article investigates the case in which the attribution of zero profits to an agency PE could arise. In order to provide a detailed examination of the topic, the authors provide a possible example as a case study analysis

The scope of this working paper is to analyse to what extent the Intellectual Property Box regimes (“IP Boxes”) adopted in the European Union are compatible with the State aid legislation. What is understood during the analysis is that the introduction of a “nexus”, like the one imposed...

This paper analyzes the use of intellectual property rights and the most common forms of tax measures to incentivize innovation and conducts a comparative analysis between the policies adopted by the US and the European Union. The first part of the paper will focus on intellectual property...

In 2020, Italy has implemented its Digital Services Tax (DST), in line with the one proposed by the European Commission and then implemented by other countries such as the U.K., France and India. The objective of the tax is to tax the “digital giants”. As the first payment of this tax will...

The aim of this paper is to illustrate the main features and issues related to the concept of corporate residence, showing to what extent it can have an impact on the provision of dividend relief. To this purpose, I will use the examples of the UK and the US, analysing the concept of residence...

The COVID-19 pandemic seems to have eclipsed the environmental crisis. Of course, priorities on the European (and international) political agenda have radically changed due to the dramatic health emergency and its devastating economic effects. The sharp reduction in global economic activity...