Ciccioriccio e Associati 
1.Italian Tax Authorities clarify the boundaries of the in-bound workers regime The ruling replies no. 71 and 74 of 12 March 2025 provide some clarifications on the concept of “high qualification or specialization” referred to into Art. 5(1)d) of the Legislative Decree 209/2023 in connection to the in-bound workers regime. … Read more
1.The longer time threshold also applies for self-employed benefitting from the in-bound workers Pursuant to ruling no. 22 of 7 February 2025, in order to benefit from the in-bound workers regime, the requirement of having spent six or seven years abroad (instead of the ordinary three pursuant to Article 5(1) … Read more
1. Tax credit on dividends from foreign sources The AIDC rule of conduct no. 227/2025 assesses the options for the recovery of taxes paid abroad on dividends, even where the latter are taxed in Italy in the hands of individuals through the 26% rate substitute tax. Indeed, according to the … Read more
1. Ratification of the new double tax treaty between Italy and People’s Republic of China Law no. 182 of 18 November 2024 on the ratification and execution of the new double taxation agreement between Italy and the People’s Republic of China was published in the Official Gazette no. 283 of … Read more
1. The Italian Tax Authorities issues clarifications on the new tax residency rules With the Circular Letter no. 20/2024 the Italian Tax Authorities examined the amendments made by Legislative Decree no. 209/2023 to the Italian rules aimed at establishing the tax residence residence of individuals and legal entities, which are … Read more
1. The Italian Tax Authorities issues clarifications on the DAC 7 With its statement of practice no. 3 of 3 October 2024, the Italian Tax Authorities have provided clarifications on the definitions of “platform” and “seller” with reference to the reporting and exchange of information obligations of digital platform operators. … Read more
1. Link between the notion of the beneficial owner and withholding taxes on dividends The decision no. 23628 of 3 September 2024 issued by the Italian Supreme Court dealt with a case whereby the plaintiff requested a refund on the Italian withholding tax paid on dividends pursuant to Art. 27-bis … Read more
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
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
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