A referendum was held on June 23, to decide whether the UK would leave or stay in the European Union. Leave won by 52% to 48%. Brexit is a reality. As a result, in the absence of precedent about the mechanism for leaving the EU (Article 50 of the Treaty on European Union), uncertainty is prevailing.
The Italian Government, by Art. 1 (clauses 142 to 144) of the 2016 Stability Law (turned into Law No. 208 of 28 December 2015, as published in the Official Gazette No. 302 on 30 December 2015), reviewed a number of tax rules to make the domestic tax system more attractive and competitive to foreign investors and Italian companies with cross-border operations.
In last couple of years, the Research & Development (R&D) Tax Incentive has caught significant importance in the international scenario, particularly in times of strong economic recession where innovation is seen as a key driver to encourage investments and produce economic growth.
On 21 April 2015 the Italian Government issued a package of measures (International Tax Decree and Certainty Decree) which significantly changes the tax rules applicable to cross-border operations and gives a specific definition to the concept of abuse of law and tax avoidance.