Ciccioriccio e Associati

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.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

1. Employment income is taxable in both residence and work State With its decision no. 5524 of 1 March 2024, the Italian Supreme Court ruled that income from employment performed in Kazakhstan by an Italian resident is taxable in both States pursuant to the relevant provisions of the Tax Treaty … Read more

1. Boundaries to the application of the Italian black-list costs provisions With its decision no. 2960 of 1 February 2024, the Italian Supreme Court ruled that the non-deductibility regime of “black-list” costs under Article 110(9-bis) and ff. of the TUIR cannot be presumptively invoked by the Italian Tax Authorities merely … Read more