ECJ Case Law

Italian Supreme Court Rules In Favor of Taxpayer, Holds Luxembourg Holding Company As Beneficial Owner Of Interest Eligible For Withholding Tax ExemptionItalian Tax Agency Proposes 1.4 Billion Euro Tax Assessment on FIAT-FCA Merger

European Union Tax Law

Italys' Register of Trusts In Effect, First Filing Due By December 11, 2023Italy plans to repeal special tax regime for new resident workers, professional and entrepreneurs from 2024

Foreign Investments in Italian real Estate

Italian Special Tax Regime for High Net Worth Individuals, Three Years InNo Gift Tax On Transfer Of Property To Trusts, Italian Supreme Court Rules, Creating New Challenges and Planning Opportunities

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

When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax ResidencyItaly’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally Interposed

Italian Corporate Income Tax

Italian Tax Agency Rules on Italy's Foreign Branch ExemptionItaly's Ministerial Decree, Draft Tax Circular Clarify DAC6's Main Benefit Test

Italian Taxation of Companies and Businesses

Italy's Ministerial Decree, Draft Tax Circular Clarify DAC6's Main Benefit TestItalian Supreme Court Rules In Favor of Taxpayer, Holds Luxembourg Holding Company As Beneficial Owner Of Interest Eligible For Withholding Tax Exemption

Italian Taxation of Individuals

When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax ResidencyItaly’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally Interposed

Italian Taxation of Trusts

When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax ResidencyItaly’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally Interposed

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

Italy’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally InterposedItalys' Register of Trusts In Effect, First Filing Due By December 11, 2023

Trust and Estate Taxation

When Is a Trust “Resident”? Comparing U.S. and Italian Approaches to Trust Tax ResidencyItaly’s Tax Agency Rules that Beneficiary’s Power to Appoint, Revoke, and Replace Trustee Makes Trust Fiscally Interposed

U.S.-Italy Tax Treaty

Some further thoughts on the Italian Supreme Court's dividend foreign tax credit ruling: very good news for taxpayers, or a potential misunderstanding? Application of Tax Treaties To Fiscally Transparent Entities: US-Italy Perspective

Uncategorized

Italys' Register of Trusts In Effect, First Filing Due By December 11, 2023Italy plans to repeal special tax regime for new resident workers, professional and entrepreneurs from 2024

VAT

ECJ Blesses International Tax Arbitrage Transaction