Books and Articles

04-11-2013 - Taxation of capital gains to nonresident aliens

This article addresses situations in which a non-resident person realises capital gains that are subject to the Italian jurisdiction to tax.

The first scenario involves the sale of stock by a non-resident person of an Italian resident corporation engaged in an Italian trade or business that owns real estate. The second scenario involves the sale by a non-resident person of shares of a holding company organised and managed in a low-tax jurisdiction that owns an Italian resident corporation. The third scenario involves the sale by a non-resident individual of his interest in a partnership engaged in a trade or business in Italy.

The Italian tax implications of each of these scenarios are discussed, in relation both to the circumstances in which the non-resident person is an individual and to those in which the non-resident is a corporation.

ROLLE G., Taxation of capital gains to nonresident aliens, in Tax Management International Forum, n. 2, 2013, pp. 45-49.

 


 

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