The Resource Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
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The item Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- The Italian tax authorities together with the Italian tax police are sending tax questionnaires to non-Italian financial institutions and banks aimed at assessing whether the mentioned non-Italian entities have realized Italian-source income (including, inter alia, interest on loans granted to Italian individuals not acting as withholding tax agents) which has not been reported and taxed in Italy. Such tax questionnaires follow the release of Ruling 41/2018, whereby the same tax authorities stated that interest on loans, granted by a Swiss bank without an Italian permanent establishment to Italian residents, qualifies as Italian-source income to be taxed in Italy at the rate provided by the applicable tax treaty even when the borrower does not qualify as Italian withholding tax agent. This article intends to provide a preliminary description of the Italian tax rules applicable to interest on loans granted to Italian residents by non-Italian resident banks also in light of the recent changes in laws and recent guidelines issued by the Italian tax authorities
- Language
- eng
- Label
- Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
- Title
- Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
- Language
- eng
- Summary
- The Italian tax authorities together with the Italian tax police are sending tax questionnaires to non-Italian financial institutions and banks aimed at assessing whether the mentioned non-Italian entities have realized Italian-source income (including, inter alia, interest on loans granted to Italian individuals not acting as withholding tax agents) which has not been reported and taxed in Italy. Such tax questionnaires follow the release of Ruling 41/2018, whereby the same tax authorities stated that interest on loans, granted by a Swiss bank without an Italian permanent establishment to Italian residents, qualifies as Italian-source income to be taxed in Italy at the rate provided by the applicable tax treaty even when the borrower does not qualify as Italian withholding tax agent. This article intends to provide a preliminary description of the Italian tax rules applicable to interest on loans granted to Italian residents by non-Italian resident banks also in light of the recent changes in laws and recent guidelines issued by the Italian tax authorities
- Citation source
- In: Derivatives and financial instruments. - Amsterdam. - Vol. 21 (2019), no. 4 ; 10 p
- http://library.link/vocab/creatorName
-
- Marciante, T
- Pittori, M
- Geographic coverage
- International
- Language note
- English
- http://library.link/vocab/subjectName
-
- banking
- foreign bank
- source of income
- interest
- loan
- income classification
- domestic tax law
- PE
- entity approach
- tax treaty
- Label
- Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
- Label
- Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Italian-tax-regime-applicable-to-interest-on/ZA2g3gw2lGw/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Italian-tax-regime-applicable-to-interest-on/ZA2g3gw2lGw/">Italian tax regime applicable to interest on loans granted by non-Italian resident banks to Italian residents : certain considerations in light of the recent positions of the Italian tax authorities</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
