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  • Service: Tax, International Executive Services
  • Type: Regulatory update, Survey report
  • Date: 2/26/2014

Income Tax 

Taxation of international executives
Tax returns and compliance
Tax rates
Residence rules
Termination of residence
Economic employer approach
Types of taxable compensation
Tax-exempt income
Expatriate concessions
Salary earned from working abroad
Taxation of investment income and capital gains
Additional capital gains tax (CGT) issues and exceptions
General deductions from income
Tax reimbursement methods
Calculation of estimates/prepayments/withholding
Relief for foreign taxes
General tax credits
Sample tax calculation


All information contained in this document is summarized by KStudio Associato, the Italian member firm of KPMG International, based on the Italian Unified Income Tax Code DPR 22 December 1986.


Tax returns and compliance

When are tax returns due? That is, what is the tax return due date?


The Italian income tax return has to be filed electronically by 30 September. If this date falls on a Saturday or Sunday, then the due date is the next working day.


What is the tax year-end?


31 December.


What are the compliance requirements for tax returns in Italy?


Residents and non-residents


Income tax is due generally by 16 June of the subsequent year; or if this date falls on a Sunday the next working day; however, the Italian Revenue can accept delayed payments within 30 days with a low interest (0.4 percent).


Two advance payments for the current year also are due and they are based on the previous year's tax liability.


Spouses are taxed separately on their earned income. Furthermore, each spouse is generally taxed on half the income from community property and on half the income of minor children.


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Tax rates

What are the current income tax rates for residents and non-residents in Italy?


Residents


Income tax table for 2014


Taxable income bracket Total tax on income below bracket Tax rate on income in bracket
From EUR To EUR EUR Percent
0 15,000 0 23
15,001 28,000 3,450 27
28,001 55,000 6,960 38
55,001 75,000 17,220 41
75,001 Over 25,420 43

In addition to the personal income tax, the regional tax is also due on the same taxable income and the percentage depends on the decision of the region in which the individual has his/her domicile. Generally the additional regional tax is charged at progressive rates between 0.7 percent and 2.03 percent.


In addition to the personal income tax, the municipal tax also is due on the same taxable income and the percentage depends on the decision of the Italian municipality in which the individual has his/her domicile. Generally, the additional municipal tax percentage ranges between 0 percent and 0.9 percent.


An advance payment has been introduced for an additional municipal income tax starting from the calendar year 2007 to be paid as a one-off payment together with the income tax balance due for the previous year in the amount of 30 percent of the tax due for the previous year.


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Residence rules

For the purposes of taxation, how is an individual defined as a resident of Italy?


An individual will be considered to be an Italian resident for tax purposes, subject to double taxation treaty provisions, if one of the following conditions is met.


  • The individual is registered in the Office of Records of the Resident Population for the greater part of the tax year (183 days or more).
  • The individual stays for the greater part of the tax year in the territory of the state (183 days or more).
  • The individual has his/her center of business or economic interests in Italy for the greater part of the tax year (183 days or more).

It is enough that only one of the three aforementioned conditions is met, even without continuity, for the greater part of the tax year, to qualify the individual as an Italian tax resident.


Is there, a de minimus number of days rule when it comes to residency start and end date? For example, a taxpayer can’t come back to the host country for more than 10 days after their assignment is over and they repatriate.


Any day or part of a day spent in Italy during the tax year has to be taken into consideration.


What if the assignee enters the country before their assignment begins?


Any day or part of a day spent in Italy during the tax year has to be taken into consideration.


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Termination of residence

Are there any tax compliance requirements when leaving Italy?


It is important to proceed with the cancellation from the register of the Italian Resident Population, the so-called "Anagrafe della Popolazione Residente" if the taxpayer has been previously enrolled in it.


What if the assignee comes back for a trip after residency has terminated?


Any day or part of a day spent in Italy during the tax year has to be taken into consideration.


Communication between immigration and taxation authorities


Do the immigration authorities in Italy provide information to the local taxation authorities regarding when a person enters or leaves Italy?


Yes.


Filing requirements


Will an assignee have a filing requirement in the host country after they leave the country and repatriate?


The assignee is responsible to file the Italian income tax return and pay the related income tax for the year of repatriation according to the normal rules and templates.


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Economic employer approach1

Do the taxation authorities in Italy adopt the economic employer approach when interpreting Article 15 of the OECD treaty? If no, are the taxation authorities in Italy considering the adoption of this interpretation of economic employer in the future?


According to new international practices (e.g. the new OECD Commentary on paragraph 2, Article 15) and the latest official rulings by Italian Tax Authorities which have shown they are increasingly taking a restrictive approach, the taxation authorities in Italy are adopting the economic employer approach.


De minimus number of days2


Are there a de minimus number of days before the local taxation authorities will apply the economic employer approach? If yes, what is the de minimus number of days?


There is no de minimus number of days before the local taxation authorities will apply the economic employer approach.


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Types of taxable compensation

What categories are subject to income tax in general situations?


Income from employment consists of all compensation in-money or in-kind received during the calendar year deriving from an employment relationship even if paid by third parties.


Below is a list of typical items of an expatriate compensation package that will be considered fully taxable, unless otherwise indicated:


  • base salary
  • school tuition reimbursement (unless special conditions are met)
  • foreign location allowances
  • employer contribution to rent
  • reimbursement of foreign and/or home country taxes
  • free or below-market-value use of employer furnished accommodation
  • home leave
  • company car, for the share attributable to the private use of the car
  • shares given to employees, which are taxable at their fair market value.

Providing that some conditions are met, some of the earlier compensation items can be exempted fully or partially from taxation.


The below-mentioned benefits are also considered taxable.


  • Loans to employees - Loans granted to employees (whether Italians or expatriates) are considered employment income. The value of the taxable benefit is equal to 50 percent of the difference between the interest calculated by applying the official rate of discount and the interest calculated by applying the rate allowed by the employer.
  • Transfer - The first allowance for the transfer of an expatriate from Italy to abroad be excluded from taxation, subject to an amount equal to 50 percent of the allowance up to EUR4,648.11.
  • Travel - Traveling expenses (flight tickets, etc.), without limit, connected with the transfer of an expatriate and his/her family are excluded from taxation if they are supported by appropriate documentation.

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Tax-exempt income

Are there any areas of income that are exempt from taxation in Italy? If so, please provide a general definition of these areas.


Payments, which are not regarded as taxable compensation, include certain payments for social welfare, life, accident insurance, medical insurance and the reimbursement of business expenses upon presentation of the original receipts.


Social welfare


Mandatory social security contributions paid by the taxpayer are tax deductible from the taxable income.


Voluntary social security and welfare contributions paid in accordance with legal requirements, even if paid abroad are tax-deductible up to the annual limit of EUR5,164.57 and under certain conditions.


Medical insurance


Contributions of up to EUR3,615.20, for medical assistance made to Italian National Medical Service Funds (Fondi Integrative al Servizio Sanitario Nazionale) both by the employer and the employee are not taxable.


Reimbursement of business expenses


The reimbursement of any business expenses incurred by the employee is not considered taxable compensation if the expenses are supported by the related original receipts.


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Expatriate concessions

Are there any concessions made for expatriates in Italy?


There are no special exclusions from taxable income for particular items received by expatriates in Italy and no particular categories of income are excluded from taxation simply because the taxpayer is an expatriate.


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Salary earned from working abroad

Is salary earned from working abroad taxed in Italy? If so, how?


Individuals who are considered tax resident in Italy and who are employed outside of Italy in a continuative and exclusive way staying out of Italy for more than 183 days in a 12-month period will be taxed on a conventional salary.


The so-called conventional salary is an amount established each year by a proper decree of the Italian Ministry of Labor, Treasure and Finance, and usually utilized for paying Italian social security contributions when the Italian employee is seconded to a non-social security treaty country. Italian employers have to operate the withholding of income taxes on the monthly conventional salary for their Italian employees working abroad. When the conventional salary is applicable, all the benefits linked and related to the foreign employment activity are considered included in the conventional salary. Consequently, it may be possible that an Italian employee seconded abroad is subject to double taxation (in Italy and in the host country) if he/she maintains tax residency in Italy. The double taxation can be avoided through the tax credit mechanism.


Furthermore, these particular rules are not applicable for Italian employees who are seconded abroad and break Italian tax residency.


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Taxation of investment income and capital gains

Are investment income and capital gains taxed in Italy? If so, how?


The tax treatments for both Italian and foreign dividends are summarized below:


Italian dividends


Recipient Non-qualifying shareholding Qualifying shareholding
Private person (dividend taxed as income from capital) 20% final withholding tax upon deduction of tax withheld at source Progressive taxation on 49.72% of the dividend (100% if the capital gains derive from a company resident in a black-listed country)

Gains from stock option exercises


Residency status Taxable at:
Grant Vesting time Exercise
Resident N N Y
Non-resident N N Y
Other (if applicable) N/A N/A N/A

Foreign dividends


Recipient Non-qualifying shareholding Qualifying shareholding
Private person (dividend taxed as income from capital) 20% final withholding tax Progressive taxation on 49.72% of the dividend, if coming from a company resident in a white-listed country (100% if the shareholding comes from company resident in a black-listed country)

Additional 10 percent tax on financial sector employees:


The Italian Tax Authorities have recently introduced the additional 10 percent tax on variable remuneration that exceeds three times the fixed remuneration received by banking and financial sector executives.


Interest


Generally, interest income is taxable. There are, however, very different taxation rules for financial instruments, according to the source of the interest. In particular, interest income from government bonds is subject to a final withholding tax of 12.5 percent.


Interest income and income from other securities issued by banks or companies listed on the stock exchange, are subject to a final withholding tax of 20 percent.


Interest on bank and postal current accounts and interest on bank and postal deposits are subject to a final withholding tax of 20 percent. Interest on foreign bank accounts can be subject to a 20 percent substitute tax via the income tax return.


Wealth tax on investments held abroad (IVAFE)


In addition to income taxes, a Wealth tax is also charged on financial assets held abroad by individual tax resident in Italy(including current accounts). The rate of Wealth tax is increased from 0,15 percent in 2013 to 0,20 percent of the value of the financial assets for 2014. For bank accounts held in EU/EEA states the tax rate is substituted by a flat rate charge of EUR34.20 per account. If the annual average in a bank account is less than EUR5,000, the wealth tax is not charged.


In addition to the Wealth Tax, all foreign investments not held through an Italian intermediary are subject to reporting for fiscal monitoring purposes (Form RW of the tax return).


Principal residence gains and losses


Capital gains realized on real property in Italy are usually taxable whether or not the owner is resident in Italy. Italian tax laws provide that capital gains realized by a transfer for consideration of buildings held for less than five years are to be included in the individual’s taxable income. The sale of the first habitual dwelling is not taxed as capital gain if the building has been used as habitual dwelling for the greater part of the possession period.


A capital gain realized on the sale of real estate purchased for more than five years is not taxable.


The capital gain realized on real properties out of Italy are taxable in Italy on the basis of the earlier-mentioned rules if the owner is considered an Italian tax resident.


(see below for Wealth Tax and Fiscal Monitoring requirements for Foreign owned Real Estate)


Investment funds


Distributions derived from the foreign investment funds - set up in accordance to EU regulations - are subject to a flat tax at a 20 percent rate. Alternatively, the foreign investment funds - not recognized accordingly to EU regulations - are subjected to Italian progressive taxation.


Real estate


The rental income from land and buildings owned abroad are considered as taxable income for Italian resident taxpayers and subject to the individual’s marginal tax rate on the foreign taxable income.


A Wealth Tax is charged on Real Estate held abroad by an Italian tax resident (whether rented out or not). Broadly, the tax at the rate of 0.76 percent is applied to the purchase price of any foreign real estate owned by an Italian tax resident. For properties located in an EU/EEA member state , it is possible to use the taxable base for local wealth taxes instead of the purchase price. The tax rate is reduced where the real estate is used as a primary residence. Where foreign wealth taxes are also applied then a Foreign Tax Credit may be available in Italy.


In addition to the payment of Wealth Taxes, a tax resident of Italy is also required to declare the value of Real Estate held abroad Italy under the fiscal monitoring rules (Form RW of the tax return)


Personal use items


Care should be taken that certain personal use items held abroad by an Italian tax resident are subject to reporting in Italy under the fiscal monitoring rules (Form RW of the tax return). These would include, inter alia, works of art, yachtsa, luxury vehicles, precious metals and jewelry. While wealth taxes are not currently charged on these items, violating the fiscal monitoring returns may lead to severe sanctions.


Gifts


Not applicable.


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Additional capital gains tax (CGT) issues and exceptions

Are there additional capital gains tax (CGT) issues in Italy? If so, please discuss?


In accordance with Italian tax law - Article 67, Paragraph 1 of the revised Italian Tax Code, which entered into force on 1 January 2004 - capital gains are treated as miscellaneous income.


The tax is levied on the spread between the selling price and the purchase cost, which may be increased by any additional legal and administrative expenses.


The taxation is applied in two different ways.


  • For an individual with a non-qualifying shareholding in a company, capital gains are subject to a 20 percent substitute tax to be paid through the filing of the income tax return.
  • For an individual with a qualifying shareholding in a company, capital gains are taxable up to the limit of 49.72 percent, and are subject to progressive IRPEF tax rates.

Capital losses


Capital losses can be carried forward for five years and used to offset capital gains of the same nature.


Are there capital gains tax exceptions in Italy? If so, please discuss?


Pre-CGT assets


Not applicable.


Deemed disposal and acquisition


Special anti-avoidance rules may be applicable.


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General deductions from income

What are the general deductions from income allowed in Italy?


There is a new system of deductions from the gross tax payable, depending on different types of income, such as employment, self-employment, or pension income. These deductions are reduced progressively until, at income levels of over EUR55,000, they no longer apply.


Family deductions


The deductions for family dependents are allowed as deductions from gross tax due.


The basic deduction for a spouse with income of less than EUR2,840.51 is EUR800; however, this amount is reduced progressively for incomes up to EUR15,000. For income between EUR15,000 and EUR40,000, the basic deduction is fixed at EUR690. For incomes in excess of EUR40,000, the EUR690 deduction is progressively reduced down to zero for income exceeding EUR80,000.


Basic deduction for a child is EUR950. This is increased by:


  • EUR250 for each child less than three years old
  • EUR400 for each child, where there are three or more children in the family
  • EUR400 for each disabled child.

These amounts are decreased as income rises as follows.


  • For an individual with one child, the deduction no longer applies at income of over EUR95,000.
  • For taxpayers with two children, the deduction is not available for income over EUR110,000.
  • For three children, the deduction is not available for income over EUR125,000.
  • For four children, the deduction is not available for income over EUR140,000.
  • For five children, the deduction is not available for income over EUR155,000.

A further deduction applies for individuals with four or more dependent children. The deduction is equal to EUR1,200, regardless to the amount of income.


These deductions are also available to non-residents; however, they will need to be able to prove the family relationship by means of a local family relationship certificate.


According to special rules, the following additional deductions from aggregate income are allowable.


  • Alimony paid to a former spouse, excluding child support payments, for the amount established by the court.
  • Social security and welfare contributions paid in accordance with legal requirements, even if paid abroad.
  • Voluntary social security contributions paid in Italy up to the limit of EUR5,164.57 and provided that further conditions are met.
  • Mandatory social security contributions paid for household staff, babysitter, and elderly-care assistants up to EUR1,549.37 per year.

A tax relief of up to a maximum of 19 percent of the following deducible expenses is allowed only to resident taxpayers.


  • Medical expenses exceeding EUR129.11 in any year, incurred by the taxpayer, his\her spouse, and other dependents, including those charged by specialists.
  • Voluntary life insurance premiums and accident premiums, not exceeding EUR1,291.14 provided that further conditions are met.
  • Interest paid to a bank resident in the EU in connection with mortgage loans secured by property in Italy; up to a maximum of EUR4,000 per year (if each spouse owns the property in common the deduction will be calculated in proportion to the ownership percentage).
  • Interest paid to a bank resident in the EU in connection with agricultural loans up to the declared land income.
  • Funeral expenses up to a maximum of EUR1,549.37.
  • High school tuition and university fees, not in excess of the tuition fees payable to state schools and universities.
  • Expense paid to a real estate agent, up to a maximum of EUR1,000.
  • Grants for particular public objectives.

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Tax reimbursement methods

What are the tax reimbursement methods generally used by employers in Italy?


The following are the normal methods of recognizing tax reimbursements paid by the employer:


  • current year gross-up
  • current year reimbursement
  • one-year rollover
  • loan/bonus.

To avoid ongoing Italian filing requirements, KPMG Italy suggests a gross-up be made in the year of departure.


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Calculation of estimates/prepayments/withholding

How are estimates/prepayments/withholding of tax handled in Italy? For example, pay-as-you-earn (PAYE), pay-as-you-go (PAYG), and so on.


In general, an Italian employer is required to apply monthly withholdings tax and if the employment income is the sole taxable income, the income taxes applied can be considered exhaustive and the taxpayer has no further compliance obligations.


Whereas for non-Italian employers, income taxes have to be paid by the employees as follows.


  • By 16 June of each year, the taxpayer has to pay the balance for the declaring year (which is the previous calendar year) and the first advance payment for the income tax due for the current year. The first advance payment amounts to 39.6 percent of the taxes paid for the previous calendar year.
  • By 30 November of each year, the taxpayer has to pay the second installment equal to the remaining 59.4 percent of the taxes due for the previous year.

In the event that an individual will not be resident in Italy for the current tax year, it is possible to apply for a reduction of the advance payment, which however has to be equal to the 99 percent of the actual tax payable for the historic year. If the advance payments made are lower, penalties and interest will be due.


Penalty provision


If the tax return is filed with a delay of between one and ninety days after the deadline, a penalty equal to EUR25 (1/10 of EUR 258), is due. A much higher penalty is applicable should the omitted tax return also include a foreign investment return, so called RW Form.


Furthermore, in the event that any tax is due, the following penalties for delayed payments are applicable.


  • A penalty equal to 30 percent of the unpaid income tax is due, plus interest of:
    1. 2.5 percent per year starting from 1 January 2012
    2. 2.5 percent per year starting from 1 January 2013
    3. 1 percent per year starting from 1 January 2014.

Calculated on a daily basis, starting from the date the tax should have been paid to the date the tax is paid.


  • If a tax payment is delayed but paid by the deadline for filing the following year’s income tax return, a penalty equal to 3.75 percent of the unpaid income tax is due, plus interest of:
    1. 2.5 percent per year starting from 1 January 2012
    2. 2.5 percent per year starting from 1 January 2013
    3. 1 percent per year starting from 1 January 2014.

Calculated on a daily basis starting from the date the tax should have been paid to the date the tax is paid. (This is valid only if the taxpayer files for a tax amnesty prior to the assessment.)


  • Tax returns filed with a delay of more than 90 days after the deadline are considered omitted by the Italian tax authorities, and penalties of between 120 percent and 480 percent of the tax due shall be applied plus interest of:
    1. 2.5 percent per year starting from 1 January 2012
    2. 2.5 percent per year starting from 1 January 2013.
    3. 1 percent per year starting from 1 January 2014

Calculated on a daily basis starting from the date the tax should have been paid to the date the tax is paid. In some circumstances, criminal sanctions may also be applied.


  • In case of an income tax return filed, for income taxes unpaid by the taxpayer, a penalty equal to 30 percent of the unpaid tax shall be applied, plus interest of:
    1. 2.5 percent per year starting from 1 January 2012
    2. 2.5 percent per year starting from 1 January 2013.
    3. 1 percent per year starting from 1 January 2014.

Calculated on a daily basis starting from the date the tax should have been paid to the date the tax is paid.


  • In case of an income tax return filed, but the Italian tax authorities find out that it is "unfaithful" and higher taxes should have been paid by the taxpayer, penalties of between 100 percent and 400 percent of the higher tax due shall be applied plus interest of:
    1. 2.5 percent per year starting from 1 January 2012
    2. 2.5 percent per year starting from 1 January 2013.
    3. 1 percent per year starting from 1 January 2014.

Calculated on a daily basis starting from the date the tax should have been paid to the date the tax is paid. In some circumstances, criminal sanctions may also be applied.


Pay-as-you-go (PAYG) withholding


Not applicable.


PAYG installments


Not applicable.


When are estimates/prepayments/withholding of tax due in Italy? For example, monthly, annually, both, and so on.


The prepayments are due twice as described earlier.


The withholding payment made by the Italian employer is made on a monthly basis.


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Relief for foreign taxes

Is there any Relief for Foreign Taxes in Italy? For example, a foreign tax credit (FTC) system, double taxation treaties, and so on?


If income earned outside Italy is included in the computation of aggregate income, taxes actually paid outside Italy on such income will be allowed as credits against net tax. The amount that can be credited is an amount which cannot exceed the Italian tax due on the same income, which is proportional to the ratio between foreign-source income and aggregate income, without diminishing any prior years’ losses, brought forward.


A foreign tax credit may be available only if foreign taxes are actually paid and the related income tax return has been filed with the tax authorities before the deadline for the filing of the Italian income tax return.


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General tax credits

What are the general tax credits that may be claimed in Italy? Please list below.


Not applicable.


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Sample tax calculation3

This calculation assumes a married taxpayer resident in Italy with two children whose three-year assignment begins 1 January 2012 and ends 31 December 2014. The taxpayer’s base salary is USD100,000 and the calculation covers three years.


2012
USD
2013
USD
2014
USD
Salary 100,000 100,000 100,000
Bonus 20,000 20,000 20,000
Cost-of-living allowance 10,000 10,000 10,000
Housing allowance 12,000 12,000 12,000
Company car 6,000 6,000 6,000
Moving expense reimbursement 20,000 0 20,000
Home leave 0 5,000 0
Education allowance 3,000 3,000 3,000
Interest income from non-local sources 6,000 6,000 6,000

Exchange rate used for calculation is the: USD1.00 = EUR0.7414.


Other assumptions


  • All earned income is attributable to local sources.
  • Bonuses are paid at the end of each tax year, and accrue evenly throughout the year.
  • Interest income is not remitted to Italy.
  • The individual is considered as resident in Milan
  • The housing contract is in the name of the Company.
  • The company car is used for business and private purposes and originally cost USD50,000.The employee is deemed resident in Italy throughout the assignment.
  • Tax treaties and totalization agreements are ignored for the purpose of this calculation.

Calculation of taxable income


Year-ended 2012
EUR
2013
EUR
2014
EUR
Days in Italy during year 366 365 365
Earned income subject to income tax
Salary 74,140 74,140 74,140
Bonus 14,828 14,828 14,828
Cost-of-living allowance 7,414 7,414 7,414
Net housing allowance 1,360 1,360 1,360
Company car 1,700 1,700 1,700
Moving expense reimbursement 0 0 0
Home leave 0 3,707 0
Education allowance 2,224 2,224 2,224
Total earned income 101,666 105,373 101,666
Other income 0 0 0
Total income 101,666 105,373 101,666
Deductions 0 0 0
Total taxable income 101,666 105,373 101,666

Calculation of tax liability


2012
EUR
2013
EUR
2014
EUR
Taxable income as above 101,665 105,372 101,665
Italian and regional tax thereon 38,136 39,776 38,136
Taxable foreign-source income 4,080 4,080 4,080
Italy substitute 27 percent tax thereon 816 816 816
Less:
Domestic tax rebates (dependent spouse rebate) 0 0 0
Foreign tax credits 0 0 0
Total Italian tax 36,189 37,643 36,160



1Certain tax authorities adopt an "economic employer" approach when interpreting Article 15 of the OECD model treaty which deals with the Dependent Services Article. In summary, this means that if an employee is assigned to work for an entity in the host country for a period of less than 183 days in the fiscal year (or, a calendar year of a 12-month period), the employee remains employed by the home country employer but the employee's salary and costs are recharged to the host entity, then the host country tax authority will treat the host entity as being the "economic employer" and therefore the employer for the purposes of interpreting Article 15. In this case, Article 15 relief would be denied and the employee would be subject to tax in the host country.


2For example, an employee can be physically present in the country for up to 60 days before the tax authorities will apply the economic employer approach.


3Sample calculation is based on the Italian Unified Income Tax Code DPR 22 December 1986 n.917; D.Lgs. 15 December 1997 for the Regional Taxes, n. 446, D.Lgs. 28 September 1998, n.360 and Law 27 December 2006 n. 296 for Municipal Taxes, Circular Letter 23 December 1997 n. 326/E for the types of Employment Income; D.Lgs. 21 November 1997, n.461 for Taxation of Capital Gains with update of D.M. 2 April 2008, n.2; DPR 7 December 2001, n.435 and DPR 22 July 1998, n.322 for Tax compliance rules; D.Lgs. 18 December 1997 n.471 and n.472 for the Administrative Sanctions and summarized by KStudio Associato, the Italian member firm of KPMG International.



© 2014 KPMG S.p.A., an Italian corporation and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (KPMG International), a Swiss entity. All rights reserved.

 

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Taxation of international executives