New Developments In Italian Taxation Of Image Rights

Artists, sportspersons and entrepreneurs should be aware of the latest ruling in Italy regarding the Italian taxation of income from the exploitation of image rights.

The new guidelines shed some light on this controversial and sensitive area of international taxation, adding to existing case law and OECD commentary, which up until now has only been addressed in major tax assessments and related litigations.

The Italian ruling

The Italian tax authorities were asked by an Italian film maker (company) whether the remuneration paid to a Spanish resident actress for her performances carried out in Italy were subject to Italian income tax (through the standard 30% final withholding tax).