Page:UN Treaty Series - vol 1332.pdf/171
The Government of the State of Israel and the Government of the Italian Republic, desirous of concluding a convention between them for the prevention of double taxation on estates and inheritances, have agreed upon the following articles:
Article I. The taxes to which this Convention relates are the following:
(a) In the case of Italy:
- (1) Estate tax;
- (2) The tax on the net total value of the inheritance;
(b) In the case of Israel: estate tax.
This Convention shall apply also to any such other tax on estates or inheritances of a substantially similar character as either Contracting State may impose after the signing of this Convention.
The competent authorities of the Contracting States shall notify each other at the end of every year of any material change in their fiscal legislation relating to estate and inheritance taxes.
Article II. For the purposes of this Convention:
(a) The term "Italy" means the Italian Republic;
(b) The term "Israel" means the State of Israel;
(c) The term "tax" means the tax on the net total value of the inheritance, and the estate tax, levied by Italy or the estate tax levied by Israel, as the context may require;
(d) The term "competent authority" means, in the case of Italy, the Ministry of Finance, Directorate-General of Taxes and Indirect Imposts on Business Transactions (Direzione Generale delle Tasse ed Imposte Indirette sugli Affari), and in the case of Israel, the Minister of Finance or his representative.
Article III. 1. In the case of the succession of a person who, at the time of his death, was domiciled in one of the Contracting States, the place where each of the following kinds of assets is situated shall, for the purposes of the imposition of tax, be determined solely according to the following rules:
- (a) Immovable property shall be considered situated in the place where it actually is.
- (b) Movable material assets (except such for which special provisions are laid down below) and bank notes, currency notes and other forms of money recognised as legal tender in their place of issue are considered situated in the place where they are at the time of the deceased's death or, if in transit, in the place of destination.
Vol. 1332, I-22352
- ↑ Came into force on 8 August 1973, the date of the exchange of the instruments of ratification, which took place at Jerusalem, in accordance with article XI.