Books and Articles

30-11-2007 - Nessun limite al credito di imposta per i redditi provenienti da regimi fiscali privilegiati

After the filing of a tax ruling, the Italian Tax Authorities in the Resolution n. 147/E dated June, 28th, 2007 recognized the tax credit taxes paid by a person resident in Italy on income produced in Gibraltar, a tax haven with which there is not a tax treaty. This conclusion was reached through the analysis of the conditions for having the deduction stated by Article 165, first paragraph of the Tax Code. The existence of the so-called "income earned abroad", its contribution to the determination of the total income of the resident recipient and the payment of the foreign tax “on a final basis” are independent from the residence of the non-resident person in a State or territory subject to lower taxation or from the absence of a bilateral convention against double taxation.


LOMBARDO M., Nessun limite al credito di imposta per i redditi provenienti da regimi fiscali privilegiati, in Fiscalità Internazionale, n. 5, 2007, p. 417-420.


 

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