Hello,
I am reading through the dual taxation agreement between the UK and Italy in relation to a italian pensions paid to a resident of the uk.
Now in terms of italian legislation, if someone is registered in the
local register of population you are a tax resident of Italy. However one is also resident of the uk if they spend more than 183 days in the UK.
So one can be a tax resident of both countries. Now this is where the tie-break
listed in the taxation agreement comes into play.
According to the tie break clause if someone has a permanent home in one state that that state 'wins' the residency. My question is, what happens if I have a permanent home in my name in Italy but my partner has a home in the UK, what should be consideted as my permanent home in the tie-break clause of the dual tax agreement?
thanks
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