On September 1, 2022, the Italian Supreme Court issued a ruling (n. 25698) in a case concerning a distribution from a U.S. partnership treated as a taxable dividend in Italy. The dividend was taxed by way of a substituted tax,
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Italy’s Substituted Tax Regime Applies in Case of Partly Italian-Source, Partly Foreign-Source Income
By Marco Rossi
In its Ruling n.83 of February 14, 2022, the Italian Tax Agency confirmed that Italy’s substituted tax regime (so-called flat tax, or forfeit) for high net worth individuals applies in a case in which international executives or managers of multinational…
Italy’s Tax Administration Issued Final Guidance on Taxation of Trusts, Singles Out UK “Offhore” Trusts Subject to New Anti Abuse Rule
By Marco Rossi
On October 20, 2022, Italy’s Tax Administration issued Circular 34/E providing final guidance on the Italian taxation of trusts. One section of the guidance discusses the new anti-abuse rule on the taxation of income distributions from foreign trusts to Italian…
Italian Tax Administration Issued Its Final Guidance on Taxation of Trusts, Discusses Italian Gift Tax On Distributions From Foreign Trusts
By Marco Rossi
On October 20, 2022 the Italian Tax Administration issued Circular n. 34/E (Circolare Trust n. 34 del 20 ottobre 2022) providing final guidance on Italian taxation of trusts. One issue addressed in Circular 34 deals with the application…
Disregarded Trust Still Complete For Italian Gift and Estate Tax Purposes, Italian Tax Agency Says
By Marco Rossi
In its Ruling n. 359 of July 4, 2022 (Risposta_351_18.05.2021-2) the Italian Tax Agency ruled that a trust which is disregarded for income tax purposes under the standards of Circular n. 61/E of December 27, 2010 is still…
Italy’ Tax Agency Rules on Interplay Between HNWIs’ Flat Tax and Taxation of Italian Source Employment Income
By Marco Rossi
With its Resolution n. 83 of 2-14-2022, the Italian Tax Agency ruled on interaction between the Italian special tax regime for high net worth individuals (so called “flat tax” or “lump sum tax” regime) and taxation of Italian source…
Discretionary Beneficiary of Irrevocable Trust Required to Disclose Trust on Italian Tax Return
By Marco Rossi
With its ruling n. 693 of October 8, 2021 (Prassi – AGENZIA DELLE ENTRATE – Risposta 08 ottobre 2021, n. 693), the Italian Tax Agency held that a discretionary beneficiary of a foreign irrevocable trust, treated as a…
Italian Tax Agency Rules on Italy’s Foreign Branch Exemption
By Marco Rossi
With tax ruling n. 18/2022 of January 12, 2022 (Risposta_18_12.01.2022), the Italian tax agency ruled that for the foreign branch tax exemption to apply, a permanent establishment must exist in the foreign jurisdiction, fully taxable in the host…
Foreign Employer’s Italian-Based Remote Worker Eligible For Special Tax Regime, Italy’s Tax Administration Rules
By Marco Rossi
In a series of recent tax rulings, Italy’s Tax Administration ruled that “remote workers” who live in and work remotely in Italy for a foreign employer with no trade or business in Italy can still qualify for the benefits of…
Italian Tax Administration Rules On Tax Classification and Source Of Income From a CEO Employment Agreement For The Purpose of Italy’s HNWIs Special Tax Regime
By Marco Rossi
In response to a petition we presented on behalf of the taxpayer, the Italian Revenue Agency issued an advance tax ruling in a case concerning the determination of the tax character and the source (place of production) of taxpayer’s income…