Fictitious foreign company residency is an elusive phenomenon that consists in the dissociation between the formal and the effective residence of legal entities. It entails various consequences in the fiscal,...
The rules governing tax residence of non-residents in Italy have been recently amended by Legislative Decree No. 209/2023. The changes introduced concern the connecting criteria, which are provided as alternatives,...
The Tax residence's regime of legal entities in Italy has been amended by Legislative Decree No. 209/2023. The amendments concern the connecting factors, provided as alternatives, for the attribution of...
The Increasing transboundary movement of people challenges a traditional keystone of fiscal regulations, progressively eroding the territorial and static work-model upon which these have been developed, in particular from the...
A person who acts on behalf of a foreign enterprise and habitually concludes contracts or acts for that purpose, can give rise to an agency permanent establishment in Italy, according...
For a permanent establishment to be constituted, there are a number of conditions that must be met and need to be verified in each single case. According to the Italian...