Add to ORKGThe author discusses a Decision by the Italian Ministry of finance dealing with the application of the DTC between Italy and Germany. More the point, a protocol annexed to the convention clarify that when an individual gets out of Germany to transfer his residence in Italy, the Italian tax authority must take into account the capital gains accrued but not yet realized in Germany. More to the point, only Germany is allowed to tax the aforementioned capital gains realized until that period, while Italy can not. This provision constitutes a good solution for the “Exit taxation” issue which is of primary importance nowadays in Europe
The author comments the forthcoming amendments to the fiscal unity regime in Italy. More to the poin...
Il presente lavoro trae spunto dalla sentenza della Corte di Giustizia dell’Unione Europea C-565/18,...
1.General: harmonization of EU and non-EU inbound dividends tax regimes and relations with other cro...
The three decisions discussed in this contribution concern the application article 24(2)(b) of the G...
This paper focuses on the foreign tax credit quantitative limitations under the Italian double taxat...
The Italian government seems to follow the work of international organisations and their fight agains...
In this contribution, the authors report on an Italian Supreme Court decision that clarifies the tax...
L'articolo analizza, in una visione comparatistica, la disciplina delle exit taxes applicate a perso...
The preliminary ruling reference (C-194/15) from the Provincial Tax Court of Turin raises the issue ...
The forthcoming approval of the Italian tax reform marks typically national intentions and patterns....
The article addresses the taxation of capital gains in the hands of non-residents, in three differen...
Source of the problem: a different level of details in the domestic and treaty rules on foreign tax ...
The limitation of the deductibility of interest in the calculation of personal and corporate income ...
The authors, in this article, examine the application of complete distributive rules as set out in v...
This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions fro...
The author comments the forthcoming amendments to the fiscal unity regime in Italy. More to the poin...
Il presente lavoro trae spunto dalla sentenza della Corte di Giustizia dell’Unione Europea C-565/18,...
1.General: harmonization of EU and non-EU inbound dividends tax regimes and relations with other cro...
The three decisions discussed in this contribution concern the application article 24(2)(b) of the G...
This paper focuses on the foreign tax credit quantitative limitations under the Italian double taxat...
The Italian government seems to follow the work of international organisations and their fight agains...
In this contribution, the authors report on an Italian Supreme Court decision that clarifies the tax...
L'articolo analizza, in una visione comparatistica, la disciplina delle exit taxes applicate a perso...
The preliminary ruling reference (C-194/15) from the Provincial Tax Court of Turin raises the issue ...
The forthcoming approval of the Italian tax reform marks typically national intentions and patterns....
The article addresses the taxation of capital gains in the hands of non-residents, in three differen...
Source of the problem: a different level of details in the domestic and treaty rules on foreign tax ...
The limitation of the deductibility of interest in the calculation of personal and corporate income ...
The authors, in this article, examine the application of complete distributive rules as set out in v...
This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions fro...
The author comments the forthcoming amendments to the fiscal unity regime in Italy. More to the poin...
Il presente lavoro trae spunto dalla sentenza della Corte di Giustizia dell’Unione Europea C-565/18,...
1.General: harmonization of EU and non-EU inbound dividends tax regimes and relations with other cro...