Abstract
The article examines the methods of taxation of financial incomes - an area on which the legislator has intervened several times during the last decades - and, in particular, the gradual expansion of the imposition at source (and substitution) in place of the taxation of financial incomes with the other incomes of the recipient, taxed with progressive rates. The historical-evolutionary approach adopted allows to deepen the reasons that led to the statement of the imposition at the source, whose preference has been, from time to time, differently explained (first with the difficulties related to tax assessment, subsequently for the opportunity to place tax obligations on intermediaries called to manage financial incomes). After the exam of the main types of income and found that imposition at the source from exception has become the rule - and new regimes provide for long-term exemptions - the article proposes some reflections on the constitutional principles of progressivity and protection of savings, to conclude that it needs to relocate financial incomes in the area of progressivity, largely sacrificed. This choice would bring the tax payer-person back to the center of the system and would not require a radical change in the current system of income taxation.
Titolo tradotto del contributo | The taxation of financial income between taxation at source and (crisis of) progressivity |
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Lingua originale | Italian |
pagine (da-a) | 443-485 |
Numero di pagine | 43 |
Rivista | RIVISTA DI DIRITTO TRIBUTARIO |
Volume | 2018 |
Numero di pubblicazione | 4 |
Stato di pubblicazione | Pubblicato - 2018 |
Keywords
- financial incomes
- imposizione sostitutiva
- progressività
- redditi finanziari
- ritenute
- witholding tax