argomento: News del mese - Diritto Internazionale e Comunitario

Articoli Correlati: copyright - transfer - royalties

On 21 October 2020, the Italian Revenue Agency published the response to ruling no. 493, as part of the Italy-Switzerland convention, analyzed the tax treatment of fees, such as royalties, paid by the transfer of the exclusive right, transferable to third parties, of phonetic reproduction and duplication of performances and interpretations as a singer.
He clarified that the more favorable tax regime provided for in Article 12, paragraph 2 of the Italy-Switzerland Convention must also be applied in our country.
Article 12, paragraph 3, of the Convention for the avoidance of double taxation provides that notwithstanding the provisions of paragraph 2, royalties under copyright and other similar compensation relating to production or reproduction of literary, dramatic, musical or artistic works, including cinematographic films or recordings for radio and television broadcasts, originating in a contracting State and paid to a resident of the other contracting State who is the beneficial owner thereof, are only taxable in that other State.