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 – MAY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1. Residence certificate and withholding refund With its decision no. 9050 of 25 April 2024, the Italian Supreme Court ruled that, in order for a foreign employee to receive the reimbursement of withholding levied by his/hers Italian employer, he/she only needs to provide the Italian Tax Authorities with a residence … Read more

INTERNATIONAL TAX FOCUS – FEBRUARY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1. Beneficial ownership requirements under the Interest&Royalty Directive According to the Italian Supreme Court decision no. 510 and 521 of 8 January 2024: in the context of the Interest&Royalty Directive (Directive 2003/49/EC), the notion of beneficial owner is to be understood as a substantive rule aimed at allocating taxing power, … Read more

INTERNATIONAL TAX FOCUS – JANUARY 2024

Ciccioriccio-Associati-PDF-Tax-Alert

1. Increase of the Italian estate taxes on foreign assets Law no. 213 of 30 December 2023 (Budget Law for 2024) provided for an increase in estate tax rates on foreign properties. In particular, as of 2024, IVIE’s rate increases from the previous 0.76% to 1.06%; IVAFE’s rate increases from … Read more

Opening of a new office in Milan.

To crown its growth, Ciccioriccio e Associati is pleased to announce the opening of a new office in Milan in order to improve and implement its ability to assist its clients in corporate, tax and administrative matters, ensuring the best professional assistance. The Milan office is in addition to the … Read more