ECJ Case Law

Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case LawItalian Supreme Court Rules In Favor of Taxpayer, Holds Luxembourg Holding Company As Beneficial Owner Of Interest Eligible For Withholding Tax Exemption

European Union Tax Law

Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case LawItalys' Register of Trusts In Effect, First Filing Due By December 11, 2023

Foreign Investments in Italian real Estate

Italy’s New Look-Through Rule Bites: Trust’s Sale of Foreign Italian-Real Estate- Holding Company’s Shares Taxable in Italy (Ruling 175/2025)Italian Special Tax Regime for High Net Worth Individuals, Three Years In

International Tax Disclosure and Compliance

When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax ResidencyItalys' Register of Trusts In Effect, First Filing Due By December 11, 2023

International Taxation

Italy Changes Course on Bonus Tax Deferment for Inbound EmployeesTaxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case Law

Italian Corporate Income Tax

Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case LawItalian Tax Agency Rules on Italy's Foreign Branch Exemption

Italian Taxation of Businesses

Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case Law

Italian Taxation of Companies and Businesses

Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case LawItaly's Ministerial Decree, Draft Tax Circular Clarify DAC6's Main Benefit Test

Italian Taxation of Individuals

Italy Changes Course on Bonus Tax Deferment for Inbound EmployeesWhen Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax Residency

Italian Taxation of Trusts

Italian Tax Agency Confirms Entity Status of Foreign Fiscally Opaque Trust, Grants Capital Gains Exemption but Denies Reduced Dividend Withholding in Ruling No. 144/2025Italy’s New Look-Through Rule Bites: Trust’s Sale of Foreign Italian-Real Estate- Holding Company’s Shares Taxable in Italy (Ruling 175/2025)

Tax Treaties

Is There a Change of Course On Split Tax Residence Year? Italian Tax Agency Rules That Italy-Switzerland Tax Treaty's Part-Year Tax Resident Provision Prevails Over Domestic Law, Refers to OECD Commentary In SupportSome further thoughts on the Italian Supreme Court's dividend foreign tax credit ruling: very good news for taxpayers, or a potential misunderstanding? 

Taxation of Trusts

Italian Tax Agency Confirms Entity Status of Foreign Fiscally Opaque Trust, Grants Capital Gains Exemption but Denies Reduced Dividend Withholding in Ruling No. 144/2025Italy’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally Interposed

Trust and Estate Taxation

Italian Tax Agency Confirms Entity Status of Foreign Fiscally Opaque Trust, Grants Capital Gains Exemption but Denies Reduced Dividend Withholding in Ruling No. 144/2025When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax Residency

U.S.-Italy Tax Treaty

Italy’s New Look-Through Rule Bites: Trust’s Sale of Foreign Italian-Real Estate- Holding Company’s Shares Taxable in Italy (Ruling 175/2025)Some further thoughts on the Italian Supreme Court's dividend foreign tax credit ruling: very good news for taxpayers, or a potential misunderstanding? 

Uncategorized

Italy Changes Course on Bonus Tax Deferment for Inbound EmployeesTaxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case Law

VAT

ECJ Blesses International Tax Arbitrage Transaction