INTERNATIONAL TAX FOCUS – SEPTEMBER 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1.Substitute tax for new residents doubles by way of the introduction of Law Decree no. 113/2024 By way of Law Decree no. 113/2024 (so-called “omnibus Decree”) the substitute tax due every fiscal year by individuals who, by transferring their tax residence to Italy, benefit from the Italian res non-dom regime … Read more

INTERNATIONAL TAX FOCUS – AUGUST 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1.Allowances for internships programs do not benefit from the in-bound workers regime According to ruling no. 152 issued by the Italian Tax Authorities on 15 July 2024, the benefits of the in-bound workers regime provided for by Art. 16 of Legislative Decree 147/2015 cannot be enjoyed by those who attend … Read more

INTERNATIONAL TAX FOCUS – JULY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1.Technical services under tax treaties concluded with Tanzania and Uganda With its ruling reply no. 120 of 3 June 2024, the Italian Tax Authorities have clarified that the following activities have, respectively, the nature of technical services (under the tax treaty concluded between Italy and Uganda) or “managerial fees” (under … Read more

INTERNATIONAL TAX FOCUS – JUNE 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1.Assonime analyses the Italian pex regime for non-residents With its circular letter no. 10 of 2 May 2024, Assonime has analysed the newly enacted participation exemption regime for non-resident companies and entities, which allows such entities to tax gains derived from the transfer of shareholdings in Italian companies considering as … Read more