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
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. 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
Foreword With the Legislative Decree no. 209 of 28 December 2023, the Italian inbound workers regime has changed once again. The amendments to the regime have the effect of rendering the regime less favourable by both reducing the exemption and providing for more stringent criteria. Previous foreign tax residence requirement … 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
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
Previous rules on tax residence of legal entities Art. 73 of the TUIR stated that companies were considered to be tax resident in Italy if, for the greater part of the fiscal year, alternatively: their legal seat was located in Italy; they were administered in Italy; the main object of … Read more
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