Tax Treaty Alert
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22-10-2024
TAX TREATY ALERT 2024/01
Continue reading »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
Continue reading »Italy and Liechtenstein sign a double taxation convention -
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 StateContinue 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 arrangementContinue reading » -
01-10-2021
TAX TREATY ALERT 2021/05
Continue reading »Italian Supreme Court rules on the interaction between Article 10 of the Italy – France Tax Treaty and the Parent Subsidiary EU Directive -
09-07-2021
TAX TREATY ALERT 2021/04
Continue reading »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 -
26-04-2021
TAX TREATY ALERT 2021/03
Continue reading »The Italian Revenue Agency rules on the application of the Partnership Report principles in relation to dividends paid to foreign fiscally transparent entities -
15-03-2021
TAX TREATY ALERT 2021/02
Continue reading »The Italian Revenue Agency clarifies the tax regime of payments for the alienation of image rights received by a Spanish resident movie actress -
27-02-2021
TAX TREATY ALERT 2021/01
Continue reading »Long duration of below the market pricing penetration strategy found not to be at arm’s length by the Italian Supreme Court -
23-10-2020
TAX TREATY ALERT 2020/06
Continue reading »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
