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what changes for subscriptions (and taxes) – Corriere.it

Netflix gets it right. The US giant in the distribution of entertainment content via the internet founded in 1997 by Reed Hastings and Marc Randolph and achieved a consolidated global turnover of 6.6 billion dollars with over 209 million subscribers worldwide (data at the end of 2020) has decided to no longer be the bad guy (bad guys in Hollywood movies speak English accent) at least with the tax authorities of European countries. This explains the decision to directly account for the turnover of subscription revenues in the country where the turnover is made. And so after France, Spain and the United Kingdom also in Italy, through the creation of an ad hoc company, Netflix Italy, we will reach a national turnover for a group which by its nature is devoted to global consumption. In practice, the revenues generated by the Italian subscriptions will be paid to a company that has been operating in our country for some time, that is Los Gatos Services Italia, which in 2020 made 19 million in revenues, a profit of 836 thousand euros and paid over 400 thousand euros in taxes. This company will change its name to Netflix Italy and from January 2022 will become the collector of all the revenues made on national soil effectively transferring to it the monthly fee payments made so far by users to the Dutch company Netflix International BV.


The litigation

This is a straightforward choice, after the renegotiation of the principles of international taxation established in the G20 and OECD headquarters to change the taxation system of multinationals and allow the application of a local tax even in the countries where distribution is carried out. of digital goods and services. In Italy, moreover, – underlines the newspaper Il Sole 24Ore – there is a specific local dispute after the Revenue Agency accused the US group of possessing a permanent establishment and essential physical infrastructures without paying taxes on the profits deriving from subscriptions. sold locally. Faced with the tightening of European and international positions against tax avoidance phenomena, Netflix has therefore decided to change its strategy.



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