Summary
The Italian Revenue Agency has published a ruling regarding the VAT implications of an Italian branch of a Luxembourg-based asset management company. The branch, which has four employees, is responsible for marketing, acquiring, and managing clients in Italy. The head office in Luxembourg deals with the management of the assets. The ruling clarifies that the branch is involved in the provision of the service by the head office, making it liable for VAT in Italy on the fees charged to clients. The ruling further states that the branch “intervenes concretely in the operations, performing a qualifying active role and operating with a certain degree of autonomy”.