Italy - Turin Tax Court Denies Treaty Residence State Dividend Exemption Absent Source Taxation
- P. Tripoli
- European Taxation, 2011 (Volume 51), No 6
- 3 May 2011
This article discusses a recent decision of the Turin Tax Court wherein the Court ruled that an Italian taxpayer shall not benefit from a full corporate tax exemption on dividends received from a German subsidiary despite the tax treaty provision that exempted the dividends from residence taxation due to the fact that no source taxation was levied in Germany.