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International Tax Focus
August Issue - Summary
ITALIAN LEGISLATION AND CASE LAW
1. Trusts interposed for direct tax purposes remain effective for civil law and inheritance tax purposes
2. Relevance of the lump-sum fee for the extension of the in-bound workers regime
3. Taxation of income deriving from crypto staking
4. Gains realised from the disposal of crypto currencies
5. Domestic and double tax treaty treatment of pension from private work activities
6. Domestic dividend withholding applied to third-Country funds is in breach of EU law
7. Challenging the Italian tax residence of a foreign established entity does not necessarily imply an abuse of law
8.CFC regime application throughout several fiscal years
9. Clarifications on how to determine the tax value of the assets of a foreign company merged into an Italian one
10. Tax treatment of a share sale by a trust
11. Amendments to the special ruling procedure regarding new investments in Italy
EU LEGISLATION AND CASE LAW
12. The Advocate General releases his opinion on Italian tax duties related to Airbnb activities
13. EU Commission urges Greece and Spain to implement rules on hybrid mismatches from the Anti-Tax Avoidance Directive
14. Italian law aimed at implementing several EU Directives become effective
TAX TREATIES
15.
Public consultation on Amount A of Pillar One
GLOSSARY
August Issue - Summary
1. Foreword
2. Res non-dom regime
2.1 Subjects in scope
2.2 Substitute Tax
2.3 Basic functioning of the regime
2.4 Ruling request
2.5 Duration
3. Inbound workers regime
3.1 Subjects in scope
3.2 Benefits of the regime
3.3 Duration
4. Pensioner regime
4.1 Subjects in scope
4.2 Benefits of the regime
4.3 Income in scope
4.4 Procedure to opt-in
4.5 Duration
4.6 Interaction with tax treaties
5. Teachers and Researchers
5.1 Subjects in scope
5.2 Benefits of the regime
5.3 Duration
5.4 Relationship between the regime and tax treaties
6. Glossary