On 14 September 2011, the Parliament approved the austerity package. The package provides for a number of measures, for a total of EUR 54.3 billion in order to guarantee that the budget will be balanced by 2013. Details of the package are summarized below.
(a) Corporate taxation.
Robin tax. In respect to the original threshold introduced in 2008 the package provides for:
|-||an increase of the additional corporate tax rate from 6.5% to 10.5% on profits exceeding EUR 10 million for companies operating in the oil, electric and renewable energy sector. This new tax rate will be applicable for three tax periods starting 1 January 2011; and|
|-||the additional corporate tax rate applies to the above companies that declare a taxable income higher then EUR 1 million.|
|-||increase to 10.5% of the corporate tax rate applicable on the deemed taxable income; and|
|-||companies which declare fiscal loss for three consecutive tax periods are subject to the non-operating companies' regime.|
Dividend form non-substantial participation.
|-||dividends distributed by resident companies or commercial entities to resident private individuals on the basis of a non-substantial participation, are subject to a final 20% withholding tax (previously, 12.5%);|
|-||the new rate will apply to dividend distributed from 1 January 2012; and|
|-||the new rate will apply also to dividends distributed to non-resident individuals, unless a lower treaty rate applies.|
The new rate makes the investment in non-substantial participation generally less attractive compared to the investment in substantial participation which are still tax exempt for 50.28%.
Taxation of interest.
Profits derived from bonds (except that derived from bonds issued by the Italian Government, EU States or states that allow an adequate exchange of information with the Italian Tax Authorities) are subject to a 20% withholding tax. The new rate will apply on interest paid from 1 January 2012.