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
Continue Reading 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
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No Transfer Taxes Apply To Distribution of Trust Property to Settlor Upon Termination of the Trust, Italy’s Supreme Court Rules
By Marco Rossi
With its ruling n. 8719 of March 30, 2021(Cass. n. 8719, 30-3-2021) the Italian Supreme Court ruled that no Italian gift tax applies when the trust assets are distributed back to the settlor, upon termination of the trust…
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Foreign Trust’s Italian Protector Not Required to Report Trust’s Foreign Financial Accounts, Italy’s Tax Agency Ruled
By Marco Rossi
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…
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U.K. Resident Non-Domiciled Individual Not a Treaty Resident Eligible For U.K.-Italy Tax Treaty Benefits, Italian Supreme Court Says
By Marco Rossi
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…
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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…
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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…
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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…
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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…
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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)…
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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…
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