JULY 2026 – INTERNATIONAL TAX FOCUS
New conventional wages approved Researcher already working in Italy may not benefit from the teachers and researchers regime The registered office of the employer is not relevant for frontier workers regime purposes Foreign tax credit shall be granted even against foreign capital gain taxes US pension funds should be taxed in Italy at the same […]
JUNE 2026 – INTERNATIONAL TAX FOCUS
Several provisions have been confirmed after the conversion of the Law Decree 38/2026 Tax payment deadline has been extended to July or August Updated the Ministerial Decree with the Countries with which Italy exchanges information Foreign tax credit shall be granted even when the tax return has not been submitted Italian domestic rules prevail over […]
MAY 2026 – INTERNATIONAL TAX FOCUS
Res non-dom and in-bound workers regime cannot be applied simultaneously. The scope of the Italian regime for foreign pensioners has been broadened. Ordinance with the form for the IRAP reimbursement on dividend has been published. Costs of employees working abroad are deductible for IRAP purposes. No participation exemption for the start-up whose activity cannot be […]
APRIL 2026 – INTERNATIONAL TAX FOCUS
Further clarifications on the inbound workers regime. Tax Authorities issue clarifications on the extensions of the teachers and researchers regime. Remunerations of self-employed artists are taxable in Italy. CFC elective system implementing rules issued by the Italian Tax Authorities. Swiss Capital Tax cannot be credited against CFC taxes in Italy. The actual benefits deriving from […]
JANUARY, FEBRUARY AND MARCH 2026 – INTERNATIONAL TAX FOCUS
Distinctions between public and private pension treatment under tax treaty law Concept of Beneficial Ownership under the Parent-Subsidiary Directive Italy Suspends Tax Treaty Benefits with Russia and Belarus Implementation and transposition of DAC 8 Directive Italy joins the Multilateral Competent Authority Agreement on the Exchange of Readily Available Information on Immovable Property (IPI MCAA) Remote […]
OCTOBER AND NOVEMBER 2025 – INTERNATIONAL TAX FOCUS
Exclusion of monthly unemployment allowance from the inbound workers regime Tax treatment of deferred compensation under the in-bound workers regime DAC 8 Implementation: Cryptoasset reporting and data exchange updates Implementation and transposition of DAC 9 Simplifications established for the duty-free reintroduction of previously exported goods Agency contracts and VAT: the ECJ clarifies the territorial scope […]
SEPTEMBER 2025 – INTERNATIONAL TAX FOCUS
Entities that place securities in the market do not qualify as withholding agents in Italy Partners of tax transparent trusts are treaty entitled if taxed on the income Italy-Russia tax treaty still applies despite the suspension decree issued in Russia Even individuals resident abroad may benefit from the “risparmio amministrato” Italian tax residence of foreign […]
AUGUST 2025 – INTERNATIONAL TAX FOCUS
Sales of real estate companies shares are relevant in Italy Proceeds derived from Italian transparent entities are taxable in Italy only if there is a PE No capital gain arises in case of transfers of residence where a PE is under the branch exemption regime Withholding levied are relevant to ascertain fair level of taxation […]
JULY 2025 – INTERNATIONAL TAX FOCUS
Game bonuses are not relevant for Italian digital tax purposes In-bound workers regime may be applied even without sending a request to the employer CFC and anti-hybrid penalty protection rules amended Assonime analyses the Italian anti-hybrid penalty protection regime VAT exemptions may still apply even when formal omissions occurred Peru ratifies and Antigua and Barbuda […]
JUNE 2025 – INTERNATIONAL TAX FOCUS
Black listed countries with reference to dividends and capital gains. Income and capital gains realized by a non resident company from the participation and from the sale of a real estate fund. Taxation of an English trust with Italian beneficiaries. Social security pensions paid by the German government to Italian beneficiaries. Requirements of the enforceable […]