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Italy - Turin Tax Court Denies Treaty Residence State Dividend Exemption Absent Source Taxation

Country:
Italy
Author:
P. Tripoli
Issue:
European Taxation, 2011 (Volume 51), No 6
Published:
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.
 
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