# Italian Tax Liability



## bosunrotty (Aug 7, 2015)

I am a British National who works and pays taxes at source in Panama. I have Panamanian residency and work permits in able to carry out my job. I have just rented a villa in Italy for a year whilst I look for a property to buy. If I apply for Italian residency will I be liable for Italian taxation on my Panamanian income given the fact that I will spend less than 100 days per year in Italy? My reason for wanting Italian residency is that I want to have Italian residency for my wife who is not an EU national.


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## BBCWatcher (Dec 28, 2012)

You would clearly be a full year tax resident of Italy in the circumstances you describe, so your worldwide income (and offshore wealth) would be taxable. Whether it's actually taxed or not is a separate question since Italy and Panama have a tax treaty, and that treaty _might_ offer some relief.


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## bosunrotty (Aug 7, 2015)

BBCWatcher said:


> You would clearly be a full year tax resident of Italy in the circumstances you describe, so your worldwide income (and offshore wealth) would be taxable. Whether it's actually taxed or not is a separate question since Italy and Panama have a tax treaty, and that treaty _might_ offer some relief.


Hi BBC Watcher

Thanks for the reply. I know that Panama & Italy have a tax treaty which I think was signed in 2013 but as far as I know it has not yet come into force and I cannot find anything that says it has. Would the fact that I am not in the country that often negate me from Italian taxation and if it did would that be a problem for my wife's residency given the EEC directive on freedom of movement etc..


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## NickZ (Jun 26, 2009)

No requirement to be in Italy. Your wife living in Italy on it's own would be enough in most cases to qualify for Italian tax residency.


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## BBCWatcher (Dec 28, 2012)

I agree with NickZ. In such circumstances you would clearly fit within the Agenzia delle Entrate's definition of Italian tax residency.

What goals are you (and your wife) trying to accomplish? If I understand those goals I might have a better suggestion.


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