OrbitaxTreaty between Italy and Belgium – Italian tax authority rules on tax qualification of payments under non-competition agreement
|Approved Changes|Italy-Belgium
On 10 June 2008, the Italian Tax Authority (ITA) issued Resolution No. 234 aimed at providing clarification with regard to the tax treatment of payments made to non-resident employees in connection with a non-competition agreement.
(a) Facts. An Italian company (the Company) carries on its chemical and pharmaceutical business in 50 countries through 400 subsidiaries. The Company has 30,000…
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