La nuova generazione di trattati italiani contro le doppie imposizioni anti condotte BEPS

Abstract. This paper examines the Treaties that Italy has recently stipulated with Colombia, Jamaica and Uruguay with regard to a central issue, that is the abuse, in respect of which the three Conventions present several innovative elements. Indeed, these new Conventions are the most advanced, inside the Italian treaty network, for a substantial profile, that is their high degree of implementation of the rules proposed by the last version of the Models (OECD, NU, US) and also by the Multilateral Convention 2016 to prevent tax planning strategies, so called, BEPS (Base Erosion and Profit Shifting). However, despite some common advanced provisions, there are several interesting differences between the three Conventions in the adoption of the various anti abuse clauses.