context, the OECD Model and its Commentary still do not give any guideline for the application of tax treaties to trust related income. Some
taxation, the State of residence may decide, being entitled to do so, to insert in a convention a provision addressed to avoid also the economic double
but to protect incumbents: there are still too many obligations to be observed which do not allow the competitive mechanism to work effectively.
Italian companies able to exploit them. The complementary two thirds do have them, according to the members of the research projects, which shows
Accademia della crusca
