The history of international tax treaties from the Italian perspective (22th November 2023)

The fiscal influence that Italy has developed internationally has played a key
role in shaping modern international taxation, both in the period between 1922
and 1946, when Italy ratified a multilateral tax treaty that constituted the first
model of an international tax convention drafted by the League of Nations, and
between 1956 and 1963, culminating in the formulation of the OECD Model.
Italy also played a leading role in the adoption of several bilateral tax treaties,
such as those signed with Czechoslovakia in 1924 and with Germany in 1925,
which introduced key concepts such as “permanent establishment” or “dual
tax residence”. Over time, through reservations, observations and a skilled interpretative
strategy, Italy has successfully preserved its fiscal policy, aimed at
favoring the source-based taxation.