Elementi innovativi dell'obbligo di accreditamento nella più recente tax treaty policy italiana

During 2020, Italy ratified three new bilateral agreements against double taxation - with Uruguay, Colombia and Jamaica - which are characterized by the provision of the discipline to contrast BEPS-type behaviors, by the approach to the most advanced models of Treaty version 2017 of the OECD and the United Nations, and by some important regulatory elements that pertain to the accreditation obligation, given the important reversals that they seem to be undertaking. This contribution intends to highlight the innovative aspects contained in the aforementioned treaties, with particular regard to the regulation of the accreditation obligation, which affirms the method that has completely replaced the exemption one.