Italy introduces rules on taxation of trusts

Article Abstract:

The Italian Parliament included a set of rules concerning the taxation of trusts in the Finance Act 2007. These rules, however, do not address, among others, the taxation of the fund sources of a trust. The Italian Tax Administration has not issued a set of guidelines regarding the application of these rules, adding to the confusion.

Trusts, Funds, Trusts, and Other Financial Vehicles, Trusts and trustees, Trusts (Law)

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The new Italian provision on the fiscal residence of foreign companies - the legislator's haste and Tax Authorities' "distractions."

Article Abstract:

Article 73 of the TUIR (Italian Tax Code) was amended by Articles 35(13) and (14) of Law Decree no. 223/06 on 4 July 2006. These amendments concern the fiscal residence of foreign companies. Taxpayers stand to suffer due to these hastily prepared measures.

Foreign corporations

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Timing issues related to the changes of the Applicable Treaty Law

Article Abstract:

Discussion on timing of amendments to the Applicable Treaty Law is presented. Provisions of the Vienna Convention on the Law of Treaties are quoted in this context.

Interpretation and construction, Treaties

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