November 4th, 2024
from 11:30 to 12:30
Several recent rulings, both on the merits and legitimacy, have delved into the application methods of the Italian mechanisms to neutralize double taxation on foreign-source income. In some cases, these rulings have identified conflicts between these mechanisms and the provisions of the current Italy-Switzerland double taxation convention. In such circumstances, the Tax Court has rightly recognized the precedence of the treaty provisions over the limitations set by domestic law, thereby overturning the denial by the Tax Administration of refund requests submitted by Italian taxpayers. It is worth noting, finally, that the consolidation of this approach may not only affect Italian-Swiss relations but could also apply to relations with other jurisdictions with which Italy has entered into a tax treaty, provided that the treaty provisions allow it. The webinar will explore the legal context and the potential effects that this jurisprudential shift in favor of taxpayers might entail if confirmed in future rulings.
Speaker
Mauro Manca
Of Counsel Terranova & Partners
Cost
CHF 150.-
Discount of CHF 50 for members of partner organizations
Registration
Registration Deadline
Thursday, 31 October 2024