Sull’inquadramento sistematico e sulla natura giuridica degli accordi preventivi per le imprese con attività internazionale e sulla loro estensibilità all’IVA

This essay will address three specific issues concerning the new institute about previous agreements for international businesses. The first issue focus on the internal structure, which, according to the most part of scholars, is not configurable as a private agreement, but as a joint exercise of tax assessment power. The second concern the relationship between the new institute and the traditional domestic rulings. The third asks if it is possibleto extend agreement effects also to VAT, particularly to the permanent establishment. The way chosen to address these issues involves a juxtaposition between the new institute and the Mutual Agreement Procedure (MAPs), with the aim to find possible common points.