Books and Articles
31-10-2009 - Recent Tax Treaty Development – Italy
Until the
beginning of works on establishment of a new model of double taxation treaty by
the Fiscal Committee of the Organization for European Economic Cooperation
(OEEC), the Italian legislator had never concluded an international double
convention on tax issues. The first approach to the practice on double tax
treaty was represented by some conventions on inheritance tax, concluded with
the United States (1955) and some European Countries. The extraordinary
negotiating activity of the second part of the XX century, due primarily to a
general tendency aimed of improving economic and politic relationships between
different Countries, slowed down in the last ten years. The present rate of
growth of the Italian tax treaty network is decreased quite permanently. A part
from some little deviations from the Model, resulting from the different
negotiation process, there are some critical aspects on which the Italian
negotiator usually asks for specific deviations from the OECD MC or pays
particular attention; they are described in this work.
LOMBARDO M., Recent Tax Treaty Development – Italy, in Michael Lang (ed.), Recent Tax Treaty Development, Wien, 2009.