Germany MOF Clarifies Taxation of Pension Payments Under 1989 DTA, Protocol With Italy

The German Ministry of Finance Feb. 26 clarified the taxation of pensions paid to Italian nationals residing in Italy, under the 1989 DTA and protocol with Italy. The clarification includes that: 1) pensions and any other recurring or non-recurring remuneration paid to Italian nationals residing in Italy must be paid under German social security law and taxed exclusively in Italy; 2) Italy may tax only the amount that would be taxable in Germany; 3) Germany will automatically issue certificates of the tax-free portion of a German pension, without applications; 4) Italian pensioners resident in Italy who will retire from 2026 ...