Italy: Ferrari to maintain tax residency

Fiat Chrysler Automobiles has confirmed that Ferrari will not be moving its tax residence from Italy, in a statement concerning the proposed separation of the two businesses.

FCA confirmed that the proposed separation of Ferrari from FCA “does not and will not entail a change in the tax residence of Ferrari. In fact, Ferrari will continue to be organized under Italian law and tax resident in Italy. Ferrari will pay Italian taxes on its income as all Italian tax resident corporations do.”

Ferrari is to be separated from FCA by way of an IPO later this year. The separation will be effected through a public offering of FCA’s interest in Ferrari equal to 10 percent of Ferrari’s outstanding shares, and a distribution of FCA’s remaining Ferrari shares to FCA shareholders.

The IPO and the subsequent distribution of shares to FCA shareholders will involve the parent company of Ferrari, which will be a Dutch incorporated entity. That structure, it was confirmed, is no different than the structure that is in place now, with FCA, also a Dutch-incorporated entity, currently being the parent company of Ferrari.

Finally, it was also confirmed that the transaction “will not shift personnel from Ferrari, nor will it reduce employment levels or activities [currently] being carried out by Ferrari in Italy. And equally important, it will not entail any reduction in the taxable base of Ferrari in Italy.”

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