Pensioni estere e dichiarazione dei redditi – Devo dichiarare la mia pensione estera?
Tutti i redditi ovunque prodotti devono essere tassati in Italia se il contribuente è ivi residente.
L’art. 3 del Tuir dispone che “L’imposta si applica sul reddito complessivo del soggetto, formato per i residenti da tutti i redditi posseduti al netto degli oneri deducibili ..”. (Principio della tassazione universale).
Affinchè un soggetto sia considerato residente all’estero è necessario:
- non essere iscritto all’anagrafe delle persone residenti in Italia per oltre 182 giorni all’anno
- essere iscritto all’AIRE (Anagrafe degli Italiani Residenti all’Estero)
- non aver avuto domicilio in Italia per oltre 182 giorni all’anno in Italia
- non aver avuto dimora abituale per oltre 182 giorni all’anno in Italia
La mancanza di uno dei suddetti recquisiti impone la tassazione di tutti i redditi in Italia (art. 3 Tuir).
Riguardo ai redditi da pensione erogate a cittadini residenti all’estero, questi sono, in generale, imponibili in Italia.
Tuttavia, con molti Paesi sono state sottoscritte Convenzioni contro le doppie imposizioni fiscali per cui ci potrebbero essere delle eccezioni alla regola generale. In tal caso, il pensionato estero può chiedere la tassazione nel suo Paese di residenza ovvero di applicare l’eventuale tassazione agevolata.
Riguardo alle pensioni estere erogate a pensionati italiani, esse sono, in linea generale, tassate in Italia. Ma anche in questi casi, trovano applicazione le Convenzioni contro le doppie imposizioni fiscali.
E’ importante, a questo punto, distinguere la natura delle pensioni percepite:
- pensioni pubbliche: erogate da uno Stato estero o da una sua suddivisione politica o amministrativa o da un ente locale; esse sono imponibili nello Stato estero
- pensioni private: eorgate da enti, istituti od organismi previdenziali dei Paesi esteri deputati all’erogazione del trattamento pensionistico; esse sono imponibili in Italia
Proprio in virtù delle Convenzioni internazionali, possiamo osservare le eccezioni applicate con alcuni Paesi:
Svizzera:
- le pensioni pubbliche sono tassate solo in Svizzera se il contribuente possiede la nazionalità svizzera; altrimenti sono tassate solo in Italia;
- le pensioni private sono tassate solo in Italia.
Le rendite corrisposte da parte dell’Assicurazione Svizzera per la vecchiaia e per i superstiti (rendite AVS) o le rendite SUVA non devono essere dichiarate in Italia in quanto assoggettate a ritenuta alla fonte a titolo di imposta.
Francia:
- le pensioni private sono tassate generalmente solo in Italia (le pensioni erogate in base alla legislazione di “sicurezza sociale” sono imponibili in entrambi gli Stati);
- le pensioni pubbliche sono tassate solo in Italia, se il contribuente ha la nazionalità italiana e non quella francese, altrimenti sono tassate solo in Francia.
Argentina, Regno Unito, Spagna, Stati Uniti, Venezuela:
- le pensioni private sono assoggettate a tassazione solo in Italia;
- le pensioni pubbliche sono assoggettate a tassazione solo in Italia, se il contribuente ha la nazionalità italiana.
Belgio, Germania:
- le pensioni private sono assoggettate a tassazione solo in Italia;
- le pensioni pubbliche sono assoggettate a tassazione solo in Italia, se il contribuente ha la nazionalità italiana e non quella estera; se il contribuente ha anche la nazionalità estera la pensione viene tassata solo in tale Paese.
Canada:
- le pensioni private e pubbliche sono assoggettate a tassazione solo in Italia se l’ammontare non supera il più elevato dei seguenti importi:
- 10.000 dollari canadesi
- 6.197,48 euro
Nel caso di superamento di tale limite, le pensioni sono tassabili sia in Italia sia in Canada e in Italia spetta il credito per l’imposta pagata in Canada in via definitiva.
Per il trattamento delle pensioni provenienti da altri paesi è necessario consultare le singole Convenzioni.
Dichiarazione dei redditi e credito d’imposta
Devono essere dichiarate nella Sezione I del quadro C del 730 ovvero RC di Unico le pensioni percepite da contribuenti residenti in Italia, prodotti in un Paese estero con il quale:
- non esiste Convenzione contro le doppie imposizioni;
- esiste Convenzione contro le doppie imposizioni in base alla quale tali redditi devono essere assoggettati a tassazione sia in Italia sia nello Stato estero;
- esiste Convenzione contro le doppie imposizioni in base alla quale tali redditi devono essere assoggettati a tassazione esclusivamente in Italia.
Solo nei primi due casi, il contribuente ha diritto ad un abbattimento sull’imposta IRPEF di pari ammontare per le imposte pagate all’estero a titolo definitivo (art. 165 del TUIR).
Tale credito d’imposta non può comunque superare la quota IRPEF relativa al reddito estero.
Nel terzo caso, invece, se i redditi sono stati tassati anche nello Stato estero di erogazione, il contribuente residente in Italia ha diritto al rimborso delle imposte pagate nello Stato estero, mediante richiesta alle autorità estere competenti e secondo le procedure da questa stabilite.
Qualora questa pubblicazione ti sia risultata utile e gradita, per rimanere sempre aggiornato iscriviti gratuitamente alla newsletter settimanale oppure seguici sui social network (facebook ).
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