According to the ruling issued by the Revenue Agency Director,
dated March 8, 2017, to gain access to the taxation ruled by the article 24 bis
of TUIR, an option application has not needed, but it’s enough an option in the
tax return.
This tax regime is an option for people who move to
Italy if they were not already resident in Italy in the last 9 years.
This tax regime, already existing in other states such
as the United Kingdom, provides for the payment, in Italy, of an annual
substitute and flat tax of EUR 100,000 (EUR 25,000 more for each family member
if he/she wishes) on foreign earnings; the income produced in Italy is subject
to ordinary taxation.
The option, automatically renewed each year, can last
up to 15 years. If you think the option is not convenient, you can opt out at
any time (obviously before the expiry time of 15 years).
The option application, that lets you to be protected
from possible notifications by the tax authorities, can be sent even before the
occurrence of the requirements needed under the TUIR.
The ruling (i.e. flat tax application) can be useful,
for example, to avoid that, a few years after the switch, the Revenue Agency
claims that the person, who has taken up residence in Italy, in the last 9
years has had the center of his/her interests (emotional, personal and / or
economic) so disregarding the option to flat tax for foreign income.
As for convenience it should be considered mainly
that:
• income produced in Italy are taxed ordinarily so if
the main income is the one produced in Italy convenience is
"attenuated"
• according to the conventions against double taxation
foreign income could be subject to taxation only in the foreign state. Opting
in the flat tax regime, foreign taxes can not be deducted from the flat tax
paid in Italy on foreign income; unless the foreign state (or some of the
foreign states) is not excluded from ‘replacement’ imposition perimeter.
So, this tax regime, I repeat It’s already used in other
states, is actually cheaper when:
• abroad income is (very) high
• Taxes paid abroad are very low (or they equal zero)
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