Article 3 of Delegated Law No. 111/2023 had indicated to the Italian Government, inter alia, the principles and guiding criteria to reform the tax system with reference to the international and supranational aspects of the tax system. In particular, the enabling act provided that the Government would have to adapt the principles of the national tax system to those established by European Union law, also taking into account the development of the case law of the Court of Justice of the European Union on tax matters, as well as ensuring the consistency of the Italian system with the OECD recommendations within the BEPS project. In this context, Legislative Decree (D.Lgs.) No. 209/2023 of 27 December was issued, which revised the rules for determining the tax residence of natural persons and legal entities by seeking to identify a criterion of actual personal connection with the territory of the State, making taxation consistent with international best practice and with the tax conventions signed by Italy. The Legislative Decree also reformed the tax regime of the so-called 'impatriate workers', partly restricting the benefits provided for by the previous legislation, but confirming the validity of the facilitation. In an attempt to simplify the complex regime for controlled foreign companies (CFCs), the Legislative Decree introduced a new substitute tax of 15% of the net accounting profit for the year. Of particular interest for the potential effects in Switzerland is the new facilitating regime introduced to favour the transfer to Italy of economic activities carried out in a foreign country not belonging to the European Union or the European Economic Area, with the reduction to 50% of income tax for six tax periods, or ten in the case of large companies.

Programme and speakers
Corporate taxation: the new criteria for tax residency
Mauro Manca
Senior Counsel, Caldara e Associati, Milan

Individuals: the new criteria for tax residency
Paolo Piantavigna
Associate Professor of Tax Law at the University of Pavia, Cassation lawyer in Milan

Reshoring and new simplified taxation for CFCs
Marco Calcagno
Certified Public Accountant, GISEV Family Office, Lugano

The new preferential regime in favour of impatriated workers
Francesco Nicolosi
Lawyer in Milan

Cost
CHF 350.
CHF 300 for members of partner institutions

Registration
https://bit.ly/webinar-31-01-2024

Registration deadline
Monday 29 January 2024