Italy Tax Agency Clarifies Taxation of Pension Income Under DTA With France

The Italian Revenue Agency July 13 posted online Letter No. 385/2023, clarifying the taxation of pension income under the 1989 DTA and protocol with France. The taxpayer, an Italian citizen living in France, received National Social Security Institute (INPS) pensions from Italy for work performed previously while living there. She sought clarification of the tax treatment of the income. The Tax Agency clarified that: 1) under Article 18 of the DTA, pensions paid under a country’s social security legislation are subject to concurrent taxation in both countries; 2) based on an exchange of notes between the countries, employee disability pensions ...