Books and Articles

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.