Tag: Citybank

Citibank is a US multinational banking and financial services corporation, operating as one of the largest global banks. It provides retail banking, corporate finance, credit, loans, and investment services through an extensive international branch and subsidiary network.

Italy vs Citybank, April 2020, Supreme Court, Case No 7801/2020

Italy vs Citybank, April 2020, Supreme Court, Case No 7801/2020

/ Permanent Establishments, Allocation of capital/equity, Article 7, Attribution of profit, Authorised OECD Approach (AOA), Bank, Citybank, Financial capacity to assume risk, Functional and factual analysis, Permanent establishment
A US Citibank branch in Italy deducted losses arising from the sale of loan agreements to a third party. Italian tax authorities denied the deductions, arguing the PE lacked financial capacity to bear the risk. After lower courts split, Italy's Supreme Court reversed the Regional Tax Court in 2020, ruling in favour of Citibank and affirming the PE's status as a distinct, autonomous entity under Article 7 ... Read more