Tax Treaty Alert

• 22-10-2024 TAX TREATY ALERT 2024/01
  

  Italian Supreme Court: foreign tax credit is due under treaty even if the foreign-sourced income was not reported in an Italian tax return

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• 20-07-2023 TAX TREATY ALERT 2023/03
  
  Italy and Liechtenstein sign a double taxation convention
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• 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
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• 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
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• 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
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• 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 
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• 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
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• 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
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• 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
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• 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
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