Italian tax treaties and domestic law: some remarks about the relationship between provisions on foreign tax credit

Source of the problem: a different level of details in the domestic and treaty rules on foreign tax credits. The particular nature of provisions on foreign tax credit and the special relationship (“a complementariness of an integrative kind”) between domestic and treaty rules. The exclusion of so-called “negative integrations” and the mere application of foreign tax credit provided for in tax treaties. The position (criticisable in rationale but correct in conclusions) of certain Regional Offices of the Italian Inland Revenue.