The European Commission confirmed that Italian anti inversion rules treating foreign companies owned or controlled by Italian national and owning or controlling Italian companies as Italian resident companies subject to tax in Italy do not violate EC law to the extent that they are designed to combat tax evasion and provide taxpayers with a reasonable opportunity to rebut the tax residency presumption and treat the foreign company as foreign and outside Italian tax net
Italy’s Supreme Court Rules Against Fictitious Foreign Tax Residency
By Marco Rossi on
Italy’s Supreme Court ruled against taxpayer in a case concerning use of fictitious tax residency for tax avoidance purposes. Italy was held to be the real tax residency as the place where taxpayer had maintained his center of main interests…