The convention against double taxation between Italy and Great Britain was signed in 1988 and ratified by Italy in 1990.

It applies to individuals who are residents of one or both of the contracting states.

The following taxes in the United Kingdom fall within its scope:

• income tax (income tax);
• corporate tax (corporation tax);
• tax on capital gains (capital gains tax);

The following taxes present in Italy fall within its field of application:

• personal income tax (IRPEF);
• income tax for legal persons (Irpeg and since 2004 Ires);
• local income tax.

“Resident of a Contracting State” means a person who, under the legislation of that State, is taxed in the same State by reason of his domicile, his residence, his registered office or any other criterion of nature analogous.

In the case of “conflict” or a person considered to be a resident of both Contracting States, the person appears to be a resident of the State in which he has permanent residence. In the presence of a permanent home in each of them the person turns out to be resident in the State in which he has the center of his economic and affective interests. However, if that person does not have a center of vital interests in either of the Contracting States or does not have permanent residence in any of them, he shall be deemed to be a resident of the State in which he normally resides.

In the event that that person habitually resides in either of the Contracting States or does not habitually reside in any of them, he shall be deemed to be a resident of the State of which he is a national and if he has the nationality of both Contracting States the situation shall be settled by common agreement by the competent authorities of the same.

For the purposes of the Convention the income derived by a resident of a Contracting State from immovable property (including those of agricultural and forestry activities) situated in the other Contracting State shall be deemed to be taxable in that other State. These incomes include those deriving from both direct use and the leasing and rental of these properties.

The profits of an enterprise of a Contracting State shall be taxable only in that State, unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.

Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State even if there are cases where such tax may also be taxed in the Contracting State of which the company paying the dividends is a resident. . This also applies to interests from a Contracting State and paid to a resident of the other Contracting State and also to royalties, although exceptions are also provided for them.