Business profits arising from the sales of electronic device

Reference no: EM132509568

"30% EBITDA rule"

In fiscal year 2019, Azzurri S.p.A. paid 70 of interest expenses, gained 25 of interest income, and has an EBITDA amounting to 100. Consistently with the "30%

EBITDA" rule, Azzurri S.p.A. will have to:
a) make a 15 downward tax adjustment in its tax return
b) amend its accountings by reducing the interest expenses to 55
c) increase its accounting result by 15
d) make a 15 upward tax adjustment in its tax return

Corporation A, which is a resident of Japan, runs a business consisting of manufacturing and selling electronic devices. A significant amount of Corporation X's customers are Ratan. The contract terms and conditions of all of the sales to Italian distributors are usually and entirely negotiated, subject to detailed instructions provided in advance by Corporation A, by Corporation B. a fully-owned subsidiary of Corporation A located in Italy. whose official business consists of marketing and customer care activities. However, all of the sales contracts to Italian distributors need to be approved and formally signed. in Japan, by Corporation A% Japanese headquarter, Which State will be entitled to levy corporate income tax on the Italian-sourced business profits arising from the sales of electronic devices?

aj Only Italy
b) Only Japan
c) Both Italy and Japan
d) Neither Italy nor Japan

Corporation A, which is a resident of Japan, runs a business consisting of manufacturing and selling electronic devices. A significant amount of Corporation X's customers are than. The contract terms and conditions of all of the sales to Italian distributors are usually and entirety negotiated. subject to detailed instructions provided in advance by Corporation A. by Corporation B. a fully-owned subsidiary of Corporation A located in It*. whose official business consists of marketing and customer care activities. However, it of the sales contracts to Italian distributors need to be approved and formally signed. in Japan. by Corporation As Japanese headquarter, Which State will be entitled to levy corporate income tax on the Italian-sourced business profits arising from the sales of electronic devices?
a) Only Italy
b) Only Japan
C) Both Italy and Japan
Neither Italy nor Japan

Reference no: EM132509568

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