Italian Supreme Court Clarifies Taxation of Capital Gains Effectively Connected to an Italian Permanent Establishment Arising from the Alienation of Immovable Properties in the State of Residence

Journal
Tenore, M.; Arginelli, P.
International; Italy; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this contribution, the authors report on an Italian Supreme Court decision that clarifies the taxation of capital gains effectively connected to an Italian permanent establishment but arising from the alienation of immovable property situated in the state of residence, under the Egypt-Italy Income Tax Treaty (1979).