December 10th, 2024
from 14:00 to 17:30
The changes introduced by Legislative Decree No. 209/2023 of December 27, 2023, had the declared purpose of aligning domestic rules for determining tax residency with greater coherence and uniformity with the principles set out by the European Union legal framework, the OECD, and the international tax treaties signed by Italy, effective from January 1, 2024, while remaining unchanged for previous tax periods. Always considering the prevailing nature of any applicable Double Taxation Treaty in the specific case, Circular No. 20/E of November 4, 2024, briefly outlines these regulatory changes to guide the operational offices in their application, referring both to legal entities and trusts, as well as to individuals. Regarding individuals, among other relevant aspects, for example, concerning the now exclusive importance of the place where the person's personal and family relationships primarily develop, the Circular provides examples for the application of the innovative and debated 鈥淧hysical Presence Criterion in the State鈥檚 Territory,鈥� based solely on the physical presence of an individual in Italy, regardless of the reasons for their presence. Regarding companies, the Circular highlights the new criteria for the place of effective management and ordinary management, emphasizing that decisions made by shareholders are not relevant for determining the place of effective management, except for those with a managerial content. According to the Circular, there have been no substantial changes regarding the residency rules for trusts and similar institutions compared to the past. Lastly, the Circular also examines the position of smart workers, both those working remotely from Italy and those working from abroad, as well as individuals benefiting from favorable regimes due to transferring their residency to Italy.
Program and Speakers
Tax Residency for Companies
Mauro Manca
Of Counsel 鈥� Terranova & Partners, Milan
Tax Residency for Individuals
Andrea Ballancin
Lawyer and Chartered Accountant, Associate Professor of Tax Law at the University of Eastern Piedmont, Partner at MB e Associati - Tax Law Firm, Milan
The 鈥淧hysical Presence鈥� Criterion and the New Border Relations between Italy and Switzerland
Paolo Piantavigna
Associate Professor of Tax Law at the University of Pavia, Lawyer with the Supreme Court Bar of Milan
Tax Residency for Trusts and Similar Institutions
Pierpaolo Angelucci
Chartered Accountant, Scarioni Angelucci, Associated Tax Firm, Milan
Cost
CHF 350.-
CHF 50.- discount for members of partner organizations
Registration
Registration Deadline
Friday, December 6, 2024