The author discusses a Decision by the Italian Ministry of finance dealing with the application of the DTC between Italy and Germany. More the point, a protocol annexed to the convention clarify that when an individual gets out of Germany to transfer his residence in Italy, the Italian tax authority must take into account the capital gains accrued but not yet realized in Germany. More to the point, only Germany is allowed to tax the aforementioned capital gains realized until that period, while Italy can not. This provision constitutes a good solution for the “Exit taxation” issue which is of primary importance nowadays in Europe.
An Italian Perspective on the Germany - Italy Tax Treaty
GREGGI, Marco
2007
Abstract
The author discusses a Decision by the Italian Ministry of finance dealing with the application of the DTC between Italy and Germany. More the point, a protocol annexed to the convention clarify that when an individual gets out of Germany to transfer his residence in Italy, the Italian tax authority must take into account the capital gains accrued but not yet realized in Germany. More to the point, only Germany is allowed to tax the aforementioned capital gains realized until that period, while Italy can not. This provision constitutes a good solution for the “Exit taxation” issue which is of primary importance nowadays in Europe.File in questo prodotto:
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