(iii) local income tax (local imposta sui redditi); (6) With regard to Article 26 (mutual agreement procedure) of the Convention, it should be considered that a tax adjustment under this article can only be made before these taxes are finally set. Moreover, in the case of Italy, the above sentence means that the use of the mutual agreement procedure does not exempt the subject from the obligation to initiate tax dispute settlement proceedings at the national level. b) An Italian resident residing in Italy who receives dividends from a company residing in the United Kingdom is entitled, subject to the provisions of paragraph (c) of this paragraph and if he is the actual beneficiary of the dividends, to the tax credit to which a person residing in the United Kingdom would have been entitled if he had received those dividends. and the payment of a possible surplus of this tax credit on its tax debt to the United Kingdom. 3. Referring to Article 26, paragraph 1 (mutual agreement procedure), the time available to the resident under the law of the contracting state is no longer reduced. 4. The provisions of paragraph 3 of this section do not apply when activities at sea are carried out in the other state for up to 30 days over a 12-month period. For the purposes of this paragraph: Expat Tax Planning Amanda Sullivan, 2019 A practical title intended to help in the planning of international orders. Chapter 7 guides the reader on the reasons for double taxation of income, the context of double taxation relief and the practical application of tax treaties. Planning points are highlighted throughout the chapter.
Request this book by e-mail (d) the term „person“ refers to a person, a corporation and any other entity of persons, but not partnerships that are not treated as tax entities in the two contracting states; Payments made for maintenance, education or training by an active student or apprentice who is or was a State party directly prior to the visit of a contracting state and who resides in the first State party for training or training purposes are not taxed in that first state, provided these payments come from sources outside that state. Income from real estate and the profits of these properties may be taxed in the country where the property is located (Articles 6 and 13). 5. The term „interest“ used in this article refers to income from government securities, bonds or bonds, whether or not they are secured by mortgages, whether or not they have the right to participate in profits, as well as receivables of any kind, as well as all other income related to income from the tax legislation of the state in which the income is generated. but does not contain income covered by Article 10 of this agreement. It is much more common to seek the services of a qualified and experienced accountant to seek tax breaks through double taxation agreements. Fees vary depending on the complexity of an individual`s personal life, in almost all cases, the tax savings far exceed all the costs of using an accountant – and they can be sure to pay the correct amount of tax with total confidence.