La compatibilità dell’imposta sui servizi digitali con le convenzioni per evitare le doppie imposizioni concluse dall'Italia

[Autom. eng. transl.] The contribution analyzes the compatibility of the Tax on digital services, introduced into the Italian legal system by the budget law for 2019 and subject to modification by the budget law for 2020, with the provisions brought by the conventions to avoid double taxation concluded by the 'Italy. In particular, it develops a plurality of arguments that support the thesis that said tax can qualify as income tax within the meaning of the aforementioned agreements (see article 2 of the same). From this premise follows the conclusion that Italy is generally barred from applying this tax to persons resident in the States with which these agreements have been concluded as a result of the contractual rules governing the taxation of business income, or - in certain limited cases - of the pact rules concerning the taxation of license fees and technical services.