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Critères pour établir la résidence fiscale en Italie

Via Roma - Turin
Via Roma – Turin

Les critères d’établissement de la résidence fiscale des personnes physiques en Italie

Les critères de détermination de la résidence fiscale des personnes physiques en Italie sont dictés par l’article 2 de la D.P.R. n. 917/1986 (“TUIR”), qui stipule qu’aux fins de l’impôt sur le revenu, les personnes physiques qui, pour la plupart de la période d’imposition sont inscrites dans les registres de population de la population résidente, sont considérées comme des résidents de l’État  ont sa résidence ou son domicile sur le territoire de l’État en vertu du Code civil. Les conditions mentionnées ci-dessus sont des alternatives; cela signifie que l’existence d’une seule d’entre elles suffit pour suggérer qu’une personne est qualifiée aux fins fiscales résidant en Italie.

La résidence à des fins civiles

Comme le prévoit expressément le droit fiscal, il convient de se référer aux notions de code civil qui, à l’article 43, dispose que “le domicile d’une personne est situé sur le lieu où il a établi le siège de son entreprise et de ses intérêts. La résidence est à l’endroit où la personne a la résidence habituelle “.

Différence entre résidence et domicile fiscal

Alors que la résidence est liée à la permanence du sujet dans un lieu suffisamment stable et à l’intention de s’y installer (données objectives); le domicile est constitué par la concentration en un lieu déterminé des affaires et des intérêts de la personne sans qu’il soit nécessaire sa présence effective en ce lieu (données objectives) ainsi que le désir d’établir et de maintenir en un lieu déterminé le “centre” principal de la généralité des relations (données subjectives). La notion d’intérêts à laquelle il convient de faire référence, une fois limitée au secteur économique et financier du sujet, doit être comprise comme se référant, par interprétation jurisprudentielle unanime, à la sphère morale, sociale et familiale du sujet. En ce qui concerne l’aspect temporel, le critère retenu par le législateur est celui de la prévalence temporelle au cours de la période d’imposition. En ce qui concerne la définition précise de la période d’imposition, il convient de se référer à l’article 7 du TUIR selon lequel la période de référence est donc l’année civile. Les résidents qui ont été dans l’une des conditions ci-dessus pendant au moins 183 jours (184 jours dans les années bissextiles) sont considérés comme des résidents.

Les paradis fiscaux

À cet égard, le législateur a récemment introduit le paragraphe 2-bis de l’article 2 du TUIR qui stipule que “sont considérés comme résidents, sauf preuve du contraire, les citoyens italiens supprimés du registre de la population de la population résidente et transférés aux États ou territoires autres que ceux identifiés par décret du ministre de l’Économie et des Finances … “Dans la pratique, les Italiens qui ont transféré leur domicile et / ou leur résidence dans des paradis fiscaux sont considérés comme résidents en Italie, sauf preuve du contraire. La résidence dans les paradis fiscaux Pour être complet, notez que la liste de pays susmentionnée, les “paradis fiscaux” peut être mise à jour conformément aux directives de l’OCDE et d’autres organismes internationaux et / ou communautaires. À cet égard, nous mentionnons quelques-uns des pays à imposition préférentielle inclus dans la liste susmentionnée en 2011 pour en citer quelques-uns: Andorre, Bahama, Barbade, Bermudes, Émirats arabes unis, Philippines, Hong Kong, Liban, Liechtenstein, Macao, Monaco, Saint-Marin, Singapour, Suisse, Vanuatu.

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