Italian Supreme Court Clarifies Taxation of Capital Gains Effectively Connected to an Italian Permanent Establishment Arising from the Alienation of Immovable Properties in the State of Residence

Abstract

In this contribution, the authors report on an Italian Supreme Court decision that clarifies the taxation of capital gains effectively connected to an Italian permanent establishment but arising from the alienation of immovable property situated in the state of residence, under the Egypt-Italy Income Tax Treaty (1979).