Abstract
[Autom. eng. transl.] The contribution is inspired by the Lombardy CTR ruling no. 1946 of 2019, concerning the taxation in Italy of the fees paid to a sports commentator, resident in the United Kingdom and subject to the tax regime of "non-domiciled residents", in consideration for the activity carried out by them in Italy. In particular, the article discusses whether the subjection to the aforementioned tax regime precludes the qualification of the commentator as a person resident for tax purposes in the United Kingdom pursuant to the agreement to eliminate double taxation concluded by Italy with that country.
| Translated title of the contribution | [Autom. eng. transl.] On the applicability of the conventions against double taxation to the so-called "UK non-domiciled tax residents" in light of the recent jurisprudential guidelines |
|---|---|
| Original language | Italian |
| Pages (from-to) | 1-5 |
| Number of pages | 5 |
| Journal | RIVISTA DI DIRITTO TRIBUTARIO |
| Volume | 2019 |
| Publication status | Published - 2019 |
Keywords
- doppie imposizioni