Abstract
Remuneration deriving from the exploitation of image rights constitutes a significant portion of earnings for artistes and sportspersons. For Italian tax purposes, the applicable tax treatment does not appear to be straightforward, above all when the underlying contractual relationship qualifies the remuneration received as miscellaneous income while the place where the image is economically exploited and the countries of residence of the payor and the payee are characterized by cross-border elements that are unrelated to each other.
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