With its private letter ruling n. 506 of October 30, 2020 (Ruling 506_2020), the Italian Tax Agency ruled that the Italian protector of a foreign trust which holds foreign financial assets and accounts to the benefit of an…
Continue Reading Foreign Trust’s Italian Protector Not Required to Report Trust’s Foreign Financial Accounts, Italy’s Tax Agency Ruled

In its Supreme Court Ruling n. 21695-2020 (issued on October 8, 2020) the Italian Supreme Court held that an individual (the “Taxpayer”) who is classified as a resident non domiciled in the U.K., is not eligible for the benefits of…
Continue Reading U.K. Resident Non-Domiciled Individual Not a Treaty Resident Eligible For U.K.-Italy Tax Treaty Benefits, Italian Supreme Court Says

Italy’s Supreme Court’s ruling n. 26965 of November 26, 2020 provides a clear example of how things can quickly turn for the worse, for an ill-advised taxpayer who fails to report a foreign financial account on his Italian income tax…
Continue Reading Italian Supreme Court Rules on Evidentiary Value of Foreign Account Documentation, Computation of Taxable Income From Undeclared Foreign Accounts

With Circular n. 33 of December 28, 2020, Italy’s Tax Agency provided administrative guidance on the special tax regime for new resident workers, professionals and entrepreneurs.

The special tax regime, amended and extended in 2019, provides a 70 percent exemption…
Continue Reading Italy’s Tax Agency Provides Clarification on Special Tax Regime for New Resident Workers, Professionals and Entrepreneurs

On November 20, 2020 Italy’s Minister of Economy and Finance published its ministerial decree dated November 17, 2020, which contains specific provisions on the meaning and enforcement of the main benefit test of COUNCIL DIRECTIVE (EU) 2018/822 of 25 May…
Continue Reading Italy’s Ministerial Decree, Draft Tax Circular Clarify DAC6’s Main Benefit Test

By now, Italian tax practitioners and tax scholars have had the opportunity to report on Italian Supreme Court’s ruling n. 14756 of July 10, 2020 (Cass.14756-20), which ruled that interest paid by an Italian operating subsidiary to its…
Continue Reading Italian Supreme Court Rules In Favor of Taxpayer, Holds Luxembourg Holding Company As Beneficial Owner Of Interest Eligible For Withholding Tax Exemption

With some years now on record after the enactment of Italy’s tax rules on special tax regime for high net worth individuals, we attach and article (Italy’s Special Tax Regime for High Net Worth Individuals, Three Years In)…
Continue Reading Italian Special Tax Regime for High Net Worth Individuals, Three Years In