08
Sep
With Ruling no. 291 of 31 August 2020 (“Ruling”), the Italian Tax Authorities (“ITA”) confirm that perpetual, equity-accounted and subordinated bonds qualify as debentures similar to bonds (titoli similari alle obbligazioni) for Italian tax purposes.
The Ruling concerns financial instruments with the following features:
they are perpetual instruments, as the issuer shall reimburse the capital only in the event of the winding-up (or other similar events) of the issuer; the early repayment may be made by the issuer at its...