The Resource Italy : introduction of the deemed residence rule and international tax planning

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

Label
Italy : introduction of the deemed residence rule and international tax planning
Title
Italy : introduction of the deemed residence rule and international tax planning
Creator
Subject
Language
eng
Summary
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?
Citation source
In: The tax specialist. - Sydney. - Vol. 11 (2008),
http://library.link/vocab/creatorName
  • Valente, P
  • Rhode, A.M
Language note
English
http://library.link/vocab/subjectName
  • residence
  • international tax planning
  • place of effective management
  • ECJ case law
Label
Italy : introduction of the deemed residence rule and international tax planning
Instantiates
Publication
Label
Italy : introduction of the deemed residence rule and international tax planning
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...