Expo Milano 2015 — tax implications for participants
By Matteo Bedogna, Studio Baldi
From 1 May 2015, Milan will be hosting Expo 2015. In addition to enjoying the numerous interesting themes presented, foreign participants will also have to deal with questions of a tax nature. Both Official Participants (countries and international organisations) or Non-Official Participants (private entities and non-governmental institutions) will be able to conduct non-commercial and commercial institutional activities in their pavilions, including the sale of products, catering and paid performances, for example.
All participants will be exempt from direct and indirect taxation in connection with institutional activities. Moreover, Official Participants will benefit from VAT exemption for purchases or imports of goods and services for non-commercial activities, up to an amount not exceeding EUR 300.
For commercial activities, it is necessary to establish if the foreign participant is a permanent establishment (PE) in Italy. In view of the fact that the event lasts six months, the Italian Tax Office considers such commercial activities as PE, with the consequent imposition of direct Italian taxation on
income. The question of PE needs to be ascertained on a case-by-case basis, with the possibility of submitting a ruling to the Tax Office.
The tax treatment enjoyed by official and non-official participants (exemption from direct and indirect tax for institutional activities) is acknowledged for general contractors who have been engaged to build and/or nun pavilions for participants.
Studio Baldi, Reggio Emilia, Parma, Italy
T: +39 0522 271 22o
Studio Baldi is a professional firm specialising in tax consulting, audit & accounting and other advisory services. Its sister company, Baldi & Partners, extends the range of services offered. Baldi & Partner is enrolled as Nominated Adviser (Nomad) on Aim Italia, the Alternative Investment Market for SMEs.
Matteo Bedogna, who joined Studio Baldi in 2001, is head of the international tax department. He specialises in transfer pricing and international tax structures. He currently assists a number of both Italian and foreign-based multinational groups.
published: November 2014