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Focus on Securitization: National Adaptation to EU Legislation

With Legislative Decree No. 131 of 3 August 2022, European Regulation No. 2017/2402 was transposed into national law.
It made significant changes to the regulatory framework of securitization transactions by introducing the figure of “simple, transparent and standardized” securitizations with the aim of forging a “virtuous” market for the financial instruments related to them.

Hybrid Mismatches: documentary burdens on taxpayers in view of the approaching deadline for the income tax return filing

Throughout the Circular, the Italian Revenue Agency pointed out that as a best practice for tax risk management, taxpayers are encouraged to perform an appropriate anti-hybrid analysis, also by cooperating with associated enterprises, to understand whether any hybrid mismatches arrangements have arisen along their organization structure before submitting the income tax return. The analysis would enable them to collect an accurate probative documentary set (“anti-hybrid Dossier”) explaining the hybrid mismatches’ assessment process they developed and implemented to determine their taxable base for income tax purposes.