Newsalert - Applicability of the substitute tax to medium long-term unregistered financing agreements


The Italian Tax Authorities have released ruling No. 956-15/2018, not published, providing certain clarifications on the possibility to apply the Italian substitute tax on medium and long-term financing agreements, and on the related security package, in case the agreements are not registered. The request for clarifications was publicly raised by the Italian Banking Association (“ABI”).

More specifically, the need for clarifications on the matter became impellent after many local offices of the Tax Authorities adopted a draconian approach according to which the substitute tax on medium long-term financing agreements and on the related guarantees could only be applied insofar as the main financing agreement had been registered with the Tax Authorities. 


See an analysis on the issue by our Tax Department