Italy Tax Agency Clarifies Tax Treatment of Management Fees Under 1979 DTA, Protocol With Egypt

The Italian Revenue Agency April 18 issued Letter No. 116/2025, clarifying the tax treatment of management fees under the 1979 DTA and protocol with Egypt. The taxpayer, a company engaged in engineering, procurement, and construction (EPC) contracting services, was fiscally resident in Italy. The taxpayer provided technical services to an Egyptian company and incurred withholding taxes in Egypt, on income derived from those services. The taxpayer sought clarification on whether it had the right, in Italy, to tax credits for the withholdings paid in Egypt on the management fees, and whether it could benefit from the tax credit for the ...