Tax Residence of Individuals in Italy: The Availability of a Permanent Home (58 European Taxation 4, 2018)

Abstract

This note discusses a recent decision of the Italian Supreme Court wherein it was held that, in determining whether an individual is resident in a state under a tax treaty's tie-breaker rule, a stay at an unregistered domestic partner's dwelling is sufficient to establish that the taxpayer "has a permanent home available to him" in a country.