1. Tax benefits for teachers and researchers returning to Italy The statement of practice no. 8 issued by the Italian Tax Authorities on 23 February 2026 provides important clarifications on the fiscal incentives for individuals returning to Italy, with a dedicated section on the special tax regime for teachers and researchers … Read more
1.New clarification on the in-bound workers regime The Italian Tax Authorities has issued some clarifications on the in-bound workers regime. With ruling no. 2 of 12 January 2026, the Italian Tax Authorities confirmed that an individual who returns to Italy to work from home for a foreign employer can benefit … Read more
1.Distinctions between public and private pension treatment under tax treaty law The Parliamentary question time no. 5-04807 addressed the issue of the different tax treatment applied to pensioners residing abroad based on the public or private nature of the pension received. It should be recalled that, when the tax treaty … Read more
1.The TNMM is applicable for low-risk reseller With its decision no. 29083 of 4 November 2025 the Italian Supreme Court held that, in line with what the Italian Tax Authorities maintained in their notice of assessment, a taxpayer may apply the TNMM method with the corrective of the ROS (Retun … Read more
1.Exclusion of monthly unemployment allowance from the inbound workers regime According to the ruling no. 228 issued by the Italian Tax Authorities on 1 September 2025, amounts paid by the State as an allowance for periods where an individual is unemployed do not fall within the scope of the former … Read more
1.Entities that place securities in the market do not qualify as withholding agents in Italy The Italian Supreme Court, with the decision no. 22419 of 4 August 2025, stated that, with respect to withholding taxes on interest and capital income referred to in Art. 26(3) of the Presidential Decree 600/73, … Read more
1.Sales of real estate companies shares are relevant in Italy With their ruling no. 175 of 4 July 2025, the Italian Tax Authorities have clarified that the capital gain derived by a US opaque trust from the sale of shareholdings in a Swiss company whose assets are represented solely by … Read more
1.Game bonuses are not relevant for Italian digital tax purposes With the statement of practice no. 6 of 3 June 2025, the Italian Tax Authorities have clarified that, in online games, gaming bonuses are not relevant to determine taxable base for digital services tax purposes (so-called “web tax”, governed by … Read more
1.Black listed countries with reference to dividends and capital gains The ruling reply no. 131 of 13 May 2025 provided clarifications on the identification of the “preferential” nature of foreign dividends (which precludes the exemption of 95% of such income). If the foreign company distributing the dividends is not controlled … Read more
1.Participation exemption regime potential in breach of EU freedoms On the 10 April 2025, the Chartered Accountants Italian Association has issued its document no. 229 which analyses the new participation exemption regime introduced in Italy with respect to capital gains derived by companies resident in the EU or EEA on … Read more