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Italy: Introduction of the deemed residence rule and international tax planning

Published on 01 Feb 08 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The introduction of the deemed residence rule in Italy, stipulating a presumption of tax residence in Italy for foreign-based companies holding a controlling participation in an Italian corporation and being either controlled or managed from Italy (“triangular structure”), stresses the long-time debate over the concept of place of effective management, the criterion adopted by the OECD to solve conflicts of dual tax residence. It is still unclear as to what rank of decision-making coincides with the “effective management”: is it the day to day supervision of business activities or the issuing of long-term directives?

Author profiles

Alan Rhode
Alan is a tax advisor with Camozzi Bonissoni Varrenti and Lecturer of EU Law at the State University of Milan. - Current at 31 March 2010
Alan Rhode
Alan is a tax advisor with Camozzi Bonissoni Varrenti and Lecturer of EU Law at the State University of Milan. - Current at 31 March 2010
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