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Newsletter

International Tax Focus - February 2023

Updated: Sep 29, 2023

International Tax Focus and International Tax In-Depth - 2/2023

 

International Tax Focus February 2023
International Tax Focus February 2023

International Tax Focus February 2023

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SUMMARY


ITALIAN LEGISLATION AND CASE LAW


1. Split-year clause under tax treaties


2. Employment work performed abroad due to COVID-19 restrictions


3. Accounting standards for Italian permanent establishment of foreign companies


4. Tax treatment for income derived by non-resident aircraft crew members


5. Tax neutrality of a cross border mergers under Italian tax law


6. Refund of the withholding applied pursuant to the Savings Directive


7. Non-resident shareholder receiving proceeds from corporate recissions


EU LEGISLATION AND CASE LAW


8. Presumption of Italian tax residency for foreign companies with not controlling Italian companies


9. Tax treatment of movie directors’ income under Italian domestic and tax treaty law


ITALIAN LEGISLATION AND CASE LAW


10. Taxation of public pension income derived by an Italian and UK citizen


11. Fashion stylists activities qualify as self-employment income even when paid to foreign companies


EU LEGISLATION AND CASE LAW

12. DAC 7 Directive on administrative cooperation between tax authorities


13. EU Parliament releases a favourable opinion on the shell companies Directive


DTT/OECD/MLI


14. Revised methodology for the BEPS Action 14 peer reviews released by the OECD



 


New Investment Management Exempion
New Investment Management Exempion


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SUMMARY


1. Foreword

2. Requirements to be met by the foreign vehicle

2.1 Foreign Investment Vehicle Location

2.2 The Independence Requirements

2.3 Absence of Senior Positions and Significant Shareholdings

2.4 The Asset Manager Remuneration

3. The two presumptions

3.1 Agency PE

3.2 Physical PE

3.3 Difference Between the Two Main Rules


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