Corporate immigration – Italian resident status commences on date of deregistration from Spanish register of companies and transfer of effective management to Italy

According to Ruling No. 9 issued by the Italian Tax Authorities on 17 January 2006, a company that transferred its residence from Spain to Italy during 2004 is subject to Italian corporate income tax (IRES) as of the date of the relocation, because the moment of the effective new resident status is the date of deregistration from the Spanish register of companies and the transfer of effective management to Italy. Details of the ruling are summarized below.

A Spanish company transf…