Italy enacts its own legislation regulating the tax treatment of Crypto-Assets
27 January 2023

Italy enacts its own legislation regulating the tax treatment of Crypto-Assets

Within the framework of the Budget Law for 2023, in force as of 1 January 2023, specific provisions dealing with the tax profiles of Crypto-Assets have been introduced in the Italian legal system.[1] Until then, in the lack of specific rules set for...
Foreign trusts and the Italian lump sum tax regime: a favourable combination
2 December 2022

Foreign trusts and the Italian lump sum tax regime: a favourable combination

Italy has not enacted an own specific legislation on the matter of trusts. However, on certain conditions, trusts are fully recognised in the Italian legal system as a result of the ratification of the the Hague Convention, come into force on 1...
RSM Force majeure clauses
9 November 2022

‘Force majeure’ – a Force 10 for 2022?

In the last year alone, fire, flood, plague and war have touched almost every continent, providing plenty of cause for parties to claim that contracts are unfulfillable for exceptional reasons.  The COVID-19 pandemic made many contractual...
Good news for Italian resident individuals perceiving income from shareholdings in foreign companies
25 October 2022

Good news for Italian resident individuals perceiving income from shareholdings in foreign companies

With judgement no. 25698 of 1 September 2022, the Italian Supreme Court made important clarifications concerning the income tax treatment of foreign dividends perceived by Italian resident individuals.
LAW IN DIGITAL SYSTEMS
4 August 2022

Law in digital systems

Insight #1 Is it possible to commit a crime in the METAVERSE?
Smart Working and the risk of Permanent Establishment
19 July 2022

Smart Working and the risk of Permanent Establishment

The ongoing digitalization of the economy has undoubtedly allowed individuals to carry out work activities from their home without being physically present in an office, and in some cases to live in Countries where their employer has not a formal...
Tax incentives. Researchers and Professors are welcome in our scientific hub
17 June 2022

Tax incentives. Researchers and Professors are welcome in our scientific hub

To support the economic, scientific and cultural development, Italy introduced many different measures, in the form of special investments, special financing or special tax regimes. From a tax perspective, with the “Brain Gain Program” the Italian...
The “arm’s length range”: clarifications for a proper interpretation provided by the Italian Revenue Agency. Approaches and tools to be adopted during the audit
14 June 2022

The “arm’s length range”: clarifications for a proper interpretation provided by the Italian Revenue Agency. Approaches and tools to be adopted during the audit

On May 24th 2022, the Italian Revenue Agency published Circular Letter n.16/E aimed at providing operational instructions on transfer pricing with respect to the ”arm's length interquartile range”.
Transfer Pricing: allocation of the burden of proof
23 May 2022

Transfer Pricing: allocation of the burden of proof

With Order No. 1374 of 18 January 2022, the Supreme Court commented again on the allocation of the burden of proof in transfer pricing disputes, pursuant to Article.
High Net Worth Individuals: the Italian "Flat Tax"
4 May 2022

High Net Worth Individuals: the Italian "Flat Tax"

INTRODUCTION  Italian tax legislation includes several measures aimed to encourage foreign individuals to move to and invest in Italy. This measure is part of a wider initiative to promote Italy as an attractive destination for workers and investors...
“Energy and Gas” Tax Credits
3 May 2022

“Energy and Gas” Tax Credits

Some legislative provisions have introduced relief measures to partially offset the higher cost borne by companies for the purchase of electricity and gas; they are summarized below: ELECTRICITY ENERGY-INTENSIVE COMPANIES
A special tax regime to attract foreign pensioners to Southern Italy – Amendments to Article 24-ter Income Tax Act
26 April 2022

A special tax regime to attract foreign pensioners to Southern Italy – Amendments to Article 24-ter Income Tax Act

“Inbound Pensioners” – General Overview In recent years, mostly inspired by the experience of other States, Italy has introduced several special tax regimes aimed at encouraging non-resident individuals to move (or to return to) and invest in the...

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