Italian Supreme Court rules that income received by fashion models falls outside the scope of article 17 OECD MC

DiPaolo ArginelliPaolo Arginelli -
Cassazione_ n. 21865-2018 With its order n. 21865/2018, the Italian Supreme Court settled a case concerning whether Italy might tax (direct or indirect) payments made to models for activities carried out in Italy in connection with the shooting of a commercial. The Supreme Court confirmed the decision of the Tax Court of Appeal of Milan (decision no. 36/32/10, of 24 February 2010), holding that such payments fall outside the scope of article 17 of the relevant Italian tax treaties (which generally follow the OECD MC), which apply only to income derived by non-resident persons as artistes (entertainers) and sportspersons. The payments made to the models were instead characterized as income fr. . .