Italy - Italian Domicile and Centre of Vital Interests: An Emigrant’s Nightmare, an Immigrant’s Dream
- Michele Gusmeroli
- European Taxation, 2009 (Volume 49), No 1
- 1 January 2009
This note briefly surveys some of the main Italian statutory provisions, Italian Supreme Court cases and rulings of the tax authorities regarding domicile (in domestic law) and the centre of vital interests (in treaty law). It then argues that an excessive focus on Italian individuals taking up residence abroad can result in a very inert centre of vital interests test, which, conversely, could benefit foreign individuals spending time in Italy.