Foreign income that partially contributes to the total taxable income – Reduction of foreign tax – Compatibility with Double Taxation Conventions – Jurisprudential guidelines

The provision of the TUIR, which requires a proportional reduction of the deductible foreign tax when foreign income only partially contributes to the taxable base, could be overridden by the rules preventing double taxation contained in many of the treaties signed by Italy, as these do not include such a provision.