Search by year



Tax Treaty Alert


  • 20-07-2023 TAX TREATY ALERT 2023/03
    Italy and Liechtenstein sign a double taxation convention
    Continue reading »
  • 29-05-2023 TAX TREATY ALERT 2023/02
    Directors’ fees fall outside Article 16 OECD Model Convention if the director is bound to remit the income to its employer in the other Contracting State
    Continue reading »
  • 07-04-2023 TAX TREATY ALERT 2023/01
    Italian Supreme Court rules out the existence of an Italian permanent establishment in a case involving a commissionaire arrangement
    Continue reading »
  • 01-10-2021 TAX TREATY ALERT 2021/05
    Italian Supreme Court rules on the interaction between Article 10 of the Italy – France Tax Treaty and the Parent Subsidiary EU Directive
    Continue reading »
  • 09-07-2021 TAX TREATY ALERT 2021/04
    The Italian Revenue Agency considers the impact of restrictions on movements of individuals caused by the COVID-19 pandemic on the application of Article 15 of the income tax treaty between Italy and China 
    Continue reading »
  • 26-04-2021 TAX TREATY ALERT 2021/03
    The Italian Revenue Agency rules on the application of the Partnership Report principles in relation to dividends paid to foreign fiscally transparent entities
    Continue reading »
  • 15-03-2021 TAX TREATY ALERT 2021/02
    The Italian Revenue Agency clarifies the tax regime of payments for the alienation of image rights received by a Spanish resident movie actress
    Continue reading »
  • 27-02-2021 TAX TREATY ALERT 2021/01
    Long duration of below the market pricing penetration strategy found not to be at arm’s length by the Italian Supreme Court
    Continue reading »
  • 23-10-2020 TAX TREATY ALERT 2020/06
    Italian Revenue Agency clarifies the treaty regime of payments for the alienation of the exclusive right in sound recordings received by a Swiss resident singer
    Continue reading »
  • 14-10-2020 TAX TREATY ALERT 2020/05
    Italian Supreme Court dealt with the existence of, and attribution of profits to, a permanent establishment in Italy
    Continue reading »