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
Marco Q. Rossi & Associati
Marco Q. Rossi & Associati is a legal organization that publishes content related to various areas of law. The firm provides insights and updates on legal matters, likely focusing on topics relevant to their practice areas. Their publications serve to inform clients and the public about legal developments, regulatory issues, and practical legal advice. The content is typically aimed at professionals and individuals seeking legal information or representation.
Website:
https://mqrassociati.com
Latest from Marco Q. Rossi & Associati - Page 4
Italian Supreme Court Rules on Evidentiary Value of Foreign Account Documentation, Computation of Taxable Income From Undeclared Foreign Accounts
By Marco Rossi
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…
Italy’s Tax Agency Provides Clarification on Special Tax Regime for New Resident Workers, Professionals and Entrepreneurs
By Marco Rossi
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…
Italy’s Ministerial Decree, Draft Tax Circular Clarify DAC6’s Main Benefit Test
By Marco Rossi
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…
Italian Supreme Court Rules In Favor of Taxpayer, Holds Luxembourg Holding Company As Beneficial Owner Of Interest Eligible For Withholding Tax Exemption
By Marco Rossi
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…
Italian Special Tax Regime for High Net Worth Individuals, Three Years In
By Marco Rossi
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)…
Preview of Italy’s Register of Beneficial Owners
By Marco Rossi
On December 23, 2019, the Italian Ministry of the Economy and Finance published on its web site a draft of the Ministerial Decree setting forth the provisions for the establishment and operation of the Register of Beneficial Owners of business…
Italian Tax Agency Proposes 1.4 Billion Euro Tax Assessment on FIAT-FCA Merger
By Marco Rossi
News broke out that Italian tax auditors have issued a proposed tax assessment for Euro 1.4 billion ($1.6 billion) as additional corporate income tax due from Fiat Chrysler Automobiles N.V. (“FCA”), in connection with the merger between FCA and FIAT…
Italian Supreme Court Upholds Ruling Denying Dividend Withholding Tax Exemption, Treaty Rate Reduction
By Marco Rossi
By way of ruling n. 25490 issued on October 10, 2019 (Supreme Court Ruling 25490 of 10-10-2019), Italy’s Supreme Court upheld the appellate court’s ruling which denied both the dividend withholding tax exemption of the EU Parent Subsidiary…
Italy Enacts New Provision On Taxation Of Distributions From Foreign Trusts
By Marco Rossi
Law Decree n. 124 of October 26th, 2019 (which is immediately effective, but needs to be converted into law within 60 days to become final) includes, at article 13, new provisions on taxation of certain distributions from foreign trusts to…