Residenza fiscale e unitarietà del periodo d'imposta: un binomio da ripensare?

[Machine translation] The time element in the notion of tax residence determines some critical issues related to the difficulty of managing the interaction between the verification of a status anchored to the principle of quantitative prevalence with respect to the tax period considered unitarily and events modifying said state (transfer of residence) or mechanisms, such as that of replacement, which, on the other hand, would require that the assessment of the same (status) be definitively ascertained in relation to a specific moment. , Hence the opportunity to reread the necessary requirement of the relevance of the link with the community from a particularly qualitative perspective, which could favor a rethinking of the current legislation towards the implementation of the so-called part-year residence, that is, a model on the basis of which, even within the same tax period, the taxpayer is subject to worldwide taxation limited to the time period in which he actually meets the requirements to be considered a resident.