Source of the problem: a different level of details in the domestic and treaty rules on foreign tax credits. The particular nature of provisions on foreign tax credit and the special relationship (“a complementariness of an integrative kind”) between domestic and treaty rules. The exclusion of so-called “negative integrations” and the mere application of foreign tax credit provided for in tax treaties. The position (criticisable in rationale but correct in conclusions) of certain Regional Offices of the Italian Inland Revenue.
Italian tax treaties and domestic law: some remarks about the relationship between provisions on foreign tax credit
CONTRINO, ANGELO
2007
Abstract
Source of the problem: a different level of details in the domestic and treaty rules on foreign tax credits. The particular nature of provisions on foreign tax credit and the special relationship (“a complementariness of an integrative kind”) between domestic and treaty rules. The exclusion of so-called “negative integrations” and the mere application of foreign tax credit provided for in tax treaties. The position (criticisable in rationale but correct in conclusions) of certain Regional Offices of the Italian Inland Revenue.File in questo prodotto:
Non ci sono file associati a questo prodotto.
I documenti in IRIS sono protetti da copyright e tutti i diritti sono riservati, salvo diversa indicazione.