income tax in italy

250 risultati per income tax in italy

  • Valutazione di vLex
  • No Taxation Of Gain From Sale of Stock of Italian Company Under Treaty, Except for Treaty Abuse, Italian Supreme Court Rules

    With its ruling n. 25219 of October 11, 2018, the Italian Supreme Court held that the capital gain realized by a German company from the sale of its shares of stock of an Italian company is exempt from corporate income tax in Italy, pursuant to Article 13, paragraph 4 of the Tax Treaty between Italy...

    ... its shares of stock of an Italian company is exempt from corporate income tax in Italy, pursuant to Article 13, paragraph 4 of the Tax Treaty ...

  • Italian International Tax Reporting Rules Through Part RW of Italian Tax Return

    Italian resident taxpayers are required to report their foreign financial investments and assets which can generate foreign-source income subject to tax in Italy, by filling out a special part of their annual income tax return referred to as form RW. Foreign individuals who have (personal and business) interests and contacts with Italy that may trigger Italian tax residency under Italian...

    ... financial investments and assets, which can generate foreign-source income subject to tax in Italy. They report their foreign investments by filling ...

  • Moving To Italy - The Resident Non-Domiciled Tax Regime

    ...This allows them to pay ordinary tax on income generated in Italy and a single, lump sum payment of €100,000 per annum, to cover tax due on non-Italian income. This is irrespective of the type, ...

  • Italy’s Supreme Courts Rules On Anti Inversion With Denial of Foreign Tax Credit

    The Italian Supreme Court, with its ruling n. 8196 of April 22, 2015 held that a NY corporation, wholly owned by an Italian company, and effectively managed and controlled by its Italian shareholders and directors in Italy, had to be treated as an Italian resident company for Italian tax purposes, and was subject to corporate...

    ... shareholders and directors in Italy, had to be treated as an Italian resident company for Italian tax purposes, and was subject to corporate income tax in Italy on all of its profits, inclusive those arising from sales to US customers in the United States. Unlike the United States, which ...

  • Impact of U.S. Federal Tax Reform From Italy’s Perspective: Renewed Attention On Italy’s Anti Inversion Rules

    As a result of the significant reduction of U.S. corporate income tax rates pursuant to the tax reform of the TCJA enacted on December 22, 2017, the Unites States now has a lower corporate tax rate than many of its trading partners, meaning that, in many instances, the profits of foreign owned or controlled-U.S. subsidiaries...

    As a result of the significant reduction of U.S. corporate income tax rates pursuant to the tax reform of the TCJA enacted on December 22, 2017, the Unites States now has a lower corporate tax rate than many of its ...

  • Highlights On The 2020 Budget Law And Related Tax Legislation

    ... institutions and insurance companies by deferring certain corporate income tax ("IRES") and local quasi-income tax ("IRAP") allowances on write-downs ... the participation is not held through a permanent establishment in Italy) can benefit from the extension of a beneficial regime available in 2019 ...

  • Italian Tax Residence For Individuals: A Refresher And Look At Open Issues And New Matters

    Italian tax residence is a very important topic for foreign nationals who travel regularly to Italy, own houses and spend significant time with their family there, while living and working abroad, as well as for those who relocate to Italy and work, do business or just retire there. For the former, it may be surprising...

    ... a very important topic for foreign nationals who travel regularly to Italy, own houses and spend significant time with their family there, while ... real estate register and, when they do not find a matching Italian income tax returns on their file, they send inquiries about the tax status of ...

  • Italy’s Tax Agency Issues Guidance on Taxation of Neo-Tax Residents Under The Fixed-Amount Tax Elective Regime

    With Circular 17/E of May 23, 2017 Italy’s Tax Agency provided administrative guidance on the interpretation and application of the provisions on the elective preferential tax regime for Italian new-tax resident individuals. New article 24-bis of Italy’s Unified Income Tax Code, enacted with Law n. 232 of December 2016, provides that foreign-resident individuals who establish...

    ...New article 24-bis of Italy’s Unified Income Tax Code, enacted with Law n. 232 of December 2016, provides that foreign-resident individuals who establish their tax residency in Italy, after ...

  • Italy’s Tax Administration Rules on Change of Tax Residency During a Tax Year

    Italy's Tax Administration rules that an individual who leaves Italy and moves to a foreign country in the second half of the year remains resident in Italy for tax purposes until the last day of the year

    ... tax residency continues through the end of that year and he or she continues to be taxable in Italy as resident on his or her worldwide income until the end of that year. The ruling clarifies that the potential double taxation that arises in the above circumstances cannot be resolved under ...

  • Italian Special Tax Regime For High Net Worth Individuals: A Review, Two Years Later

    In 2017, Italy introduced a special tax regime intended to attract Italian and foreign nationals who have been resident outside of Italy for at least nine of the previous ten years, to transfer their tax residence to Italy and pay a fixed amount of €100,000 in lieu of the Italian regular income tax on their...

    In 2017, Italy introduced a special tax regime intended to attract Italian and foreign ... and pay a fixed amount of €100,000 in lieu of the Italian regular income tax on their foreign source income. Taxpayers qualifying for the special ...

  • Overview of Italy’s Tax Provisions on Trust – Updated

    I. Introduction Italy does not have domestic rules on trust. However, trusts created under foreign law are recognized and enforceable in Italy pursuant to the provisions of the 1985 Hague Convention on the Law Applicable to Trusts and Their Recognition, which has been ratified and implemented and is fully effective in Italy as part of...

    ...They establish general principles on tax classification and treatment of trusts in Italy for income and indirect tax purposes and have significant cross-border implications   On August 6, 2007 Italy’s tax administration issued Circular n. ...

  • Reciprocal Inter Governmental Agreement Will Introduce Automatic and Reciprocal US-Italy Disclosure and Exchange of Information For Tax Purposes

    The new U.S. FATCA legislation and implementing inter governmental agreements granting reciprocal and automatic exchange of financial information between tax administrations will make international tax reporting and compliance mandatory and unavoidable, and will tax authorities with formidable tools for international audits and enforcement activities.

    ... accounts with US banks would have to make sure that: 1) those accounts are properly reported on Model RW of their Italian tax return, 2) any income arising from those accounts is properly declared and subjected to tax in Italy, 3) Italian tax on foreign investments deposited on those accounts is ...

  • European Commission Blesses Italy’s Anti-Inversion Rules

    The European Commission confirmed that Italian anti inversion rules treating foreign companies owned or controlled by Italian national and owning or controlling Italian companies as Italian resident companies subject to tax in Italy do not violate EC law to the extent that they are designed to combat tax evasion and provide taxpayers with a reasonable opportunity to rebut the tax residency...

    ... is effectively managed from Italy is treated as an Italian company for Italian tax purposes and it is subject to tax in Italy on its worldwide income. In order to prevent abusive practices consisting in putting an Italian company owned or controlled by Italian shareholders under the umbrella of a ...

  • Italy’s New Flat Tax For First-Time Residents

    Italy enacted a flat tax for first-time residents, which applies in lieu of the ordinary income tax on foreign source income. The flat tax is charged at the fixed amount of euro 100,000. Italian source income remain taxable with the ordinary income tax. First-time residents eligible for the flat tax are exempt from the duty to disclose their non Italian financial and real estate investments and...

    ...The flat tax amounts to euro 100,000 regardless of the amount of taxable income. Foreign source income is completely exempt from the regular personal income tax, while domestic source income is taxed under the general tax rules ...

  • U.S. Now a Black-Listed Country For Purpose of Italy’s CFC Rules

    Pursuant to the Tax Cuts and Jobs Act (“TCJA”) passed on Dec. 22, 2017, the U.S. will tax U.S. corporations with the following tax rates: – 21 percent general corporate income tax rate, – 13.125 effective tax rate on U.S. corporation’s foreign derived intangible income (“FDII”), for taxable years from 2018 through 2025; – 10.5...

    ...22, 2017, the U.S. will tax U.S. corporations with the following tax rates: – 21 percent general corporate income tax rate, – 13.125 effective tax rate on U.S. corporation’s foreign derived intangible income (“FDII”), for taxable years from 2018 through ...

  • The Flat Tax for individuals transferring their tax residence to Italy

    The 2017 Budget Law 2017 introduced a substitute tax optional regime (equal to € 100,000 per each tax year) for non-resident individuals wishing to transfer their tax residence to Italy.

    ... Article 1, paragraph 152, of the 2017 Budget Law introduced Article 24-bis in the Italian Income Consolidation Code ("TUIR"). Pursuant to this Article, the individuals not resident in Italy for at least nine of the ten tax years prior to the ...

  • Italian Substituted Tax On Financial Income At Odds With Tax Treaties

    Italy taxes various categories of financial income – namely dividends, interest and capital gains – earned by private investors outside the carrying on of a trade or business, by way of a substitute tax charged on the gross amount of the income at the flat rate of 26 percent. With effect from January 1, 2018,...

    Italy taxes various categories of financial income – namely dividends, interest and capital gains – earned by private investors outside the carrying on ...

  • Tax Administration’s Notices on Foreign Accounts Disclosure, Following Automatic Exchange of Information, Alert Taxpayers, Offer Opportunity To Fix Issues

    Italian international tax law rules provide that Italian tax residents with foreign financial accounts capable of generating foreign source income taxable in Italy, are under the obligation to disclose the information relating to those accounts to the Italian tax authorities. Disclosure is accomplished by filling out a proper section of the Italian personal income tax...

    ... foreign financial accounts capable of generating foreign source income taxable in Italy, are under the obligation to disclose the information ...

  • Italy Extends Statute of Limitation for Foreign investments and CFCs

    Italy Extends to 9 Years the Statute of Limitation for Income from Foreign Investments and Controlled Foreign Companies

    Italian parliament passed a new law which extends the statute of limitation for assessment of taxes due on income arising from foreign investments and controlled foreign companies. The general statute of limitation period is five years from the year in which the ...

  • The New Consolidated Corporate Income Tax Form for 2009 Addresses Interest Deduction Limitations in Consolidated Groups

    New corporate tax form for 2009 implements new provisions on deduction of interest expenses within the tax consolidated group

    Italy’s tax administration issued the new consolidated corporate income tax return form for the year 2009, with its instructions, which deals with the ...

  • Tax Administration Rules on Taxation of Foreign Stock Options

    In ruling n. 92/E of April 2, 2009 Italy’s tax administration ruled that stock received through the exercise of stock options granted by a foreign company is income taxable in Italy, if the options are  exercised after the taxpayer has moved to Italy and become a resident of Italy for tax purposes, even though the...

    In ruling n. 92/E of April 2, 2009 Italy’s tax administration ruled that stock received through the exercise of tock options granted by a foreign company is income taxable in Italy, if the options are  exercised after the taxpayer has ...

  • Trust and family and succession planning

    Trusts are very important tools for family and succession planning. Italy enacted specific provisions on the tax treatment of trusts for income tax and indirect (transfer) tax purposes. However, Italy does not have specific legislation on trusts, and trusts for Italian clients or Italian assets must be formed and operated in accordance with the legislation...

    Trusts are very important tools for family and succession planning. Italy enacted specific provisions on the tax treatment of trusts for income tax ...

  • Italy’s Tax Provisions on Trusts – Updated

    Italy operates specific provisions on tax treatment of trusts. Trusts formed under foreign law are recognized and enforced in Italy pursuant to the Hague Convention on Trusts dated July 1, 1985. To the extent they have Italian assets, or Italian grantor, trustees or beneficiaries or Italian source income, foreign trusts may be subject to Italy’s...

    ...To the extent they have Italian assets, or Italian grantor, trustees or beneficiaries or Italian source income, foreign trusts may be subject to Italy’s trust tax provisions. Under certain circumstances, trusts are disregarded and trust assets are treated as ...

  • Italy Reinforces its Foreign Assets Reporting Rules

    Italy's tax administration issued a guideline according to which all foreign assets must be reported in Italy, including personal assets (such as vacation homes, yachts, jewelery) that do not generate any foreign income taxable in Italy. The new guideline is part of a general reinforcement of foreign assets reporting rules adopted in connection with the enactment of the new tax shield, which...

    ...On February 1, the Italian tax administration approved the new income tax return forms for 2010 (for individuals and unincorporated business) and issued instructions for the preparation of the return that confirm the ...

  • Overview of Italy’s Tax Reporting Rules

    Italian resident taxpayers are required to report all of their assets held outside of Italy,  on form RW of their Italian income tax returns (which include various sections and can be considered the equivalent of the FBAR and other international tax returns that are required to be filed in the United States). Resident taxpayers subject...

    Italian resident taxpayers are required to report all of their assets held outside of Italy,  on form RW of their Italian income tax returns (which include various sections and can be considered the equivalent of the FBAR and other international tax returns that are required to ...