IBFD Alumni Section - International - Administrative Aspects of the Application of Tax Treaties - The administrative implications of the application of tax treaties are often considered to be a somewhat uninteresting subject. The author, in this contribution, however, demonstrates that the topic has great significance, especially with regard to the issue of double taxation. In this context, the ...

WHAT'S GOING ON IN ... - ITALY: RULING ON THE APPLICATION OF THE ITALIAN CFC RULES TO A MALTESE INTERNATIONAL TRADING COMPANY - Details and comments are provided regarding a recent Italian ruling on the application of the Italian controlled foreign company (CFC) rules to a Maltese International Trading Company and the tax treatment of the imputation credit and the refund of the corporate income ...

Russo, Raffaele, (2006)

INTERNATIONAL: THE 2005 OECD MODEL CONVENTION AND COMMENTARY: AN OVERVIEW - This article contains a review of the changes introduced in 2005 to the OECD Model Convention and Commentary, together with comments by the author.

Russo, Raffaele, (2005)

WHAT'S GOING ON IN ... - ITALY: ITALIAN RULING ON ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS - Details and comments are provided on Ruling No. 69 of 1 June 2005 regarding the attribution of profits to a foreign permanent establishment for Italian tax purposes. The Ruling contains interesting views on the relationship between the tax treaty and the unilateral double taxation relief methods.

Russo, Raffaele, (2005)