First issues 2022
Starting from July 2022 we will deliver a monthly tax newsletter and a special in-depth on a special tax or legal matter that have an international reach, both in english. Below the summary of the first issues and bottom page the two documents.
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July 2022 Issue - Summary
ITALIAN LEGISLATION AND CASE LAW
1. Further Italian Tax Authorities’ guidelines regarding arm’s length ranges
2. Requirements for the extension of the in-bound workers regime
3. Relevance of the permanent home for tax treaty resident status
4. Tax treatment of an insurance policy partially attributed to former spouse
5. Requirements to benefit from withholding exemption on proceeds paid by an Italian REIT
6. Threshold for transparency regime of Italian REIT
7 Non-resident companies may derive business income without a permanent establishment
8. Treatment of Italian-sourced dividends derived by a foreign pension scheme
9. Amendments enacted through the “Tax Simplification Decree”
EU LEGISLATION AND CASE LAW
10. Discriminatory provision on family and household allowances
11. Directive proposal on debt-equity bias reduction allowance
12. Further clarifications of the Italian Tax Authorities on the DAC-6 Directive
13. Extension of the deadline for submitting the self-declaration on aids received
TAX TREATIES
14. Frontier workers regulation goes back to the pre-Covid 19 status quo
15. Updates of the OECD MLI list as of 30 June 2022
16. Pillar One and Pillar Two implementation in EU
GLOSSARY
July 2022 Issue - Summary
1. Foreword
2. Outbound dividends
2.1 Exemption under the “Parent-Subsidiary” Directive
2.2 1.20% EU/EEA reduction
2.3 Tax Treaty Reduction
2.4 Domestic Withholding Tax
3. Inbound dividends
3.1 Individuals
3.2 Companies
4. Glossary