Author: Piergiorgio Valente
This volume provides a detailed analysis of the issues of companies’ tax residence and fictitious foreign residence by offering normative, interpretative, and case-law references and assessing the impact of parent companies’ leadership and coordination activities.
The book starts by dealing with a topic that is key to every tax legislation: identifying the residency of the physical or legal person on whom to exercise the tax authority, and it proceeds to address the issue, on which much Italian legislation has been written in recent years, of companies’ fictitious foreign residence.
The fundamental international law basis discussed is the identification of the seat of effective management of a company. Further, the book extensively covers the principles governing the concept of residency of legal entities within EU law, international law, and the regulation of the most important EU and non-EU countries.
This third edition features a new structure, rearranged to better address the needs of professionals and other specialized workers in the sector. The book was updated thanks to interesting new ideas coming not only from Tax Authorities but also from case-law, which has increasingly dealt with this topic creating uniformity of rulings.
Comments to the most significant sentences on the subject matter are written in a specific chapter whereas their texts are compiled in the appendix.
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