The two published responses, numbered 384 and 387, analyze the tax regime for self-employment services provided by non-residents in Italy. Both cases involve individuals with Italian citizenship who intend to establish an Italian VAT number to invoice services, none of which are for Italian clients. The common elements in the responses are Italian citizenship, foreign tax residence, provision of services to non-Italian clients, deviations from standard OECD rules in the relevant conventions with Thailand and China, and the Italian tax agency’s view that an Italian VAT position is irrelevant for determining tax residence. The responses also discuss the nature of the VAT position and the direct taxation implications for foreign residents providing services in Italy. The conventions with Thailand and China have peculiar rules, including taxation based on presence or fixed base in Italy.
Source: eutekne.info
