UK Inheritance Tax Changes
New UK Domicile Rules The UK government is in the course of making some significant, and complex, reforms to the taxation of non UK domiciled individuals. The changes impact UK Inheritance tax liabilities for people living outside the UK . Under previous rules if you had a UK domicile (and had not lost it) there […]
Tax For Digital Nomads
Compliance with Tax and Social Regulations Moving to Italy as a digital nomad comports the payment of income taxes, social security contributions according to the rules applicable to your specific situation. It is clear, from the tenor of the digital nomad visa/permesso legislation that Italy intends digital nomads to comply with their obligations in terms of tax […]
Frontier workers residing in the ‘new’ border municipalities – Special Tax Regime – Decree-Law 113/2024 (‘Omnibus’ Decree-Law)
Article 6 of Decree Law 113/2024 establishes a special regime for workers residing in municipalities, specifically identified in Annexes 1 and 2 of the DL, which are wholly or partially within the 20 km zone from the Swiss border. Such individuals may opt for the application, on income from employment received in Switzerland, of a […]
Leaving Italy – Tax Considerations
Departure From Italian Shores If you have decided to say arrivederci or adieu to the Bella Vita after a period of residence in Italy, there are a few considerations in terms of tax that you should bear in mind. Fiscal Code Number You do not need to cancel your fiscal code number and indeed there […]
Italian Statutory Tax Residence Test For Individuals: 2024 changes
The Legislative Decree on International Taxation, No. 209 of 27 December 2023 introduced some important modifications to the Italian rules on the tax residence of individuals and the statutory test of tax residence (STTR). The STTR contained in art. 2, para. 2 of the Italian Tax Code (Decree of the President of the Republic of […]
Impatriates Regime 2024
New rules for the 2024 Impatriates Regime for Individuals Legislative Decree no. 209 of 27 December 2023 was published in the Official Gazette (OG General Series No. 301 of 28-12-2023) and is stated to enter into force from 1 January 2024. The Decree, an executive measure, was approved by the Italian Council of Ministers pursuant […]
Reform of the Italian Impatriates Regime, Tax Residence Test and Incentives for Transfers of Businesses to Italy.
Reform of the Impatriates Regime The Italian Council of Ministers has approved approved the final draft text of the law modifying the Impatriates Regime. See this article for the latest information Italian Council of Ministers Press release n. 54 of 16 October 2023Reform of the Italian Impatriates Regime, Tax Residence Test and incentive for […]
“Impatriates” – 70%/90% Tax break to attract “human capital” to Italy – pre 2024 Rules
The Italian Council of Ministers in a Press Release no 54 of 16 October 2023 proposed a significant reform of the Italian Impatriates Regime. The reform was enacted by Legislative Decree Dec. 27, 2023, No. 209 which was published in the Official Gazette (OG General Series No. 301 of 28-12-2023) and is stated to enter force from 1 […]
Hiring an Employee – the Permanent Establishment risk
A non-Italian business considering employing an individual in Italy needs to consider whether the activities carried on by an Italian based employee in Italy create a corporate income tax (IRES) liability on the profit attributable those activities. Foreign corporations with a “permanent establishment” (or fixed base) in Italy generally need to register with the Register […]
Tax Step Up of Shares/Land and Buildings – Revaluation
Law Decree no. 17 of March 1, 2022, containing urgent measures for the containment of electricity and natural gas costs, the development of renewable energy and the relaunch of industrial policies, known as the Energy Decree was published in the Official Gazette no. 50 of March 1, 2022. Article 29 of the Decree confirms the […]