Italy Gazettes Press Release on Partial Suspension of 1996 DTA, Protocol With Russia

March 27, 2026, 5:00 AM UTC

The Italian Official Gazette March 24 published a press release announcing the March 13 formal notification to Russia of Italy’s partial suspension of the countries’ DTA and protocol, signed April 9, 1996. The press release announces the suspension of: 1) the DTA provisions on the taxation of permanent establishments (PEs), income from immovable property, business profits, profits from international transport, associated enterprises, dividends, interest, royalties, capital gains, income from dependent personal services, pensions, other income, and capital assets; and 2) the protocol’s provisions on determining a PE’s operating expenses, profits from international transport, redeterminations for related parties, and withholding tax ...

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