Taxation envisaged on income fees arising from professional services of a US director -for the direction of a TV series set in Italy
The answer to interpello (Question) No. 129 of 20 January 2023, issued by the Agenzia delle Entrate, offers an explanation on the taxation to be applied on payments made by an Italian film company to a US partner company, fully owned by a US-based director; the Italian Tax Agency confirms that the payments should be […]
Proceeds arising from alienation of property located in Italy by non-residents
With its Reply No. 110/2023, the Italian Revenue Agency confirms the concurrent taxing power of Italy and Spain of the proceeds deriving from the alienation of a property located on the Italian territory, purchased more than five years ago by a person currently residing in Spain. The Convention between Italy and Spain on double taxation […]
Taxation of income from the transfer of a property situated abroad in Italy
The Italian Revenue Agency clarifies a case of taxation of capital gain on the sale of property abroad under double taxation treaties.
Domestic and International Tax Reform: disclosed the initial Law Decrees envisaged by the Government Decree
The Government Decree discloses initial reforms on national and international fiscal matters.
Income from employment paid by a foreign company to a person tax resident in Italy
The Revenue Agency clarifies the case of an Italian tax resident working from Italy for a Dutch company.
Bilateral Double Taxation Conventions: the appropriate classification of personal income for treaty application purposes
The Revenue Agency confirms the remuneration of a German citizen, who is not an Italian fiscal resident and carried out an internship at Italian administrations, must exclusively be taxed in Italy.
Legal value of OECD Commentary and lack of international tax residence conflict
The OECD Commentary to the Convention Model on Double Taxation has no regulatory value, being only a direct recommendation addressed to the member countries. According to this principle, already stated by the Supreme Court in its ruling N.6242 of 2020, the Court rejected the appeal of a taxpayer, who sought the application of the OECD […]
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Tax treatment of income produced by a non-resident consultant for activities rendered to an Italian Ministry
Clarified the tax treatment of self-employment income produced by a person resident abroad for a consultancy activity rendered to an Italian Ministry.