Italian resident taxpayers are required to report their foreign financial investments and assets which can generate foreign-source income subject to tax in Italy, by filling out a special part of their annual income tax return referred to as form RW. Foreign individuals who have (personal and business) interests and contacts with Italy that may trigger Italian tax residency under Italian residency or domicile tests would be subject to the same reporting obligations. Italy’s tax administration is stepping up its enforcement efforts in this area of law and penalties for failure to report are particular harsh and difficult to mitigate after the fact. We have prepared an overview of Italian international tax reporting rules with a general discussions of some of the relevant issues that arise in this area of law.
November 2012
Italian Supreme Court Reverses Course on Permanent Establishment Issue
By Marco Rossi on
Italian Supreme courts reverses course on the issue of re-characterization of an Italian foreign owned company as permanent establishment of its foreign parent. The decisions seems to depart significantly from previously established case law stemming from the Supreme Court’s decisions in the Philip Morris case and provide more clarity to foreign businesses interested in expanding into Italy…