Italy - New Withholding Taxes on Interest Paid to Non-Resident Entities: Beneficial Ownership Requirement as a Shield against Conduit Structures
- G. Labombarda; G. Bitetti
- European Taxation, 2012 (Volume 52), No 1
- 20 December 2011
This article discusses a new provision that imposes a withholding tax of 5% on interest payments that meet all of the requirements for benefitting from the EU Interest and Royalties Directive except for the condition regarding beneficial ownership.