COMPARATIVE SURVEY: TAX TREATMENT OF SECURITIZATIONS OF RECEIVABLES: ITALY

Securitizations of receivables is an hot topic in the international taxation arena. Tax rules applicable to this kind of transactions across countries and jurisdictions differ to a great extent and very often are not specifically laid down in order to govern the tax treatment of securitizations but derive from interpretation and adaptation of general principles and of other tax provisions. Aim of the comparative survey is to provide coverage, across several jurisdictions, of corporate tax, VAT and withholding tax treatment of securitization of receivables also in the case of cross-collateralization. International tax and PE issues are closely analysed and looked at. Tax planning opportunities are highlighted.