Volume 38 (2010) / Issue 12

Piergiorgio Valente, 'Italy – Tax Audits to Identify Fictitious Corporate Residence' (2010) 38 Intertax, Issue 12, pp. 692–700


The need for a tax audit in the area of fictitious residence derives from circumstantial evidence – acquired during the intelligence phase – or from other clues that may have emerged during inspection.

Further to the cognizance gathered within an enterprise’s operative context, investigations aim at the research of accounting, supplementary, and electronic documentation. Such investigations may turn out to be particularly complex as they are generally required to consider the distinctive characteristics of international relations, the specificity of the subject matter, as well as the various jurisdictions (and legislatures) involved.

Inspectors are bound to have their operations comply to a rather structured power-duties system, within which the respect of the taxpayer’s rights acquires particular relevance.

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ISSN: 0165-2826
ID: TAXI2010073