In the year 2023, the Supreme Court issued interventions aimed at systematizing the criteria for determining the status of a beneficial owner in cases involving nonresident recipients of Italian-source income. These interventions introduced a threefold test to assess the qualifying conditions.
In his article published in “Fiscalità & Commercio Internazionale” (no.1/2024), our partner Giovanni Rolle delves into an analysis of these rulings within the context of the emerging trends derived from the latest case law in this specific domain.