Assessment of residence for tax purposes
The Firm assisted a professional football player in the litigation relating to the recovery of income deriving from sports performance abroad.
The tax argument, based on the circumstance that the subject was registered in the registry office of the resident population, was refuted on the merits, through the demonstration that the player was actually resident abroad during the disputed periods.
The Firm invoked the application of the conventional legislation in order to establish which State was entitled to tax income wherever it was produced and, in particular, in order to exclude any Italian taxing rights.
At the outcome of the proceedings at first instance, the Tax Court annulled the assessment, on the basis of Article 4 of the OECD Model Convention against double taxation.