Tax Residence in Italy. The Italian Tax Revenue Office Guidelines
Our International Tax Team in Milan has made a first comment on Circular Letter 20/E of 4th November 2024.
The Italian Administration provided its interpretation about the new rules on tax residence applicable in Italy for individuals, companies and entities since January 2024 (Leg. Decree No. 209/2023).
Always welcoming the Italian Tax Revenue Office effort for clarity, the result is an alignment with the OECD guidelines for corporate entities and partnerships.
For trusts, the new rules are not changing the principle, giving the trustee a clear right to rebut the Italian tax residence presumption, if any. For individuals, the new tax definition of domicile is commented by the Administration which provides some interesting examples with a twofold result.
Read the comment from our International Tax Team in Milan
