Newsletter

International Tax Focus 07/08 2022

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



 

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Italian tax regimes to attract foreigners
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