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Italy - The Relationship between the EU Parent-Subsidiary Directive (2011/96) and Tax Treaties under Italian Case Law: Is Double Non-Taxation Always Undesirable?

Country:
Italy
Author:
F. Capitta
Issue:
European Taxation, 2018 (Volume 58), No 12
Published:
5 November 2018
In this note, the author examines the decision of the Italian Supreme Court of Cassation in Case No. 23367/2017, given on 6 October 2017, regarding the application of a tax treaty provision to dividends received by a foreign parent company benefiting from the provisions of the EU Parent-Subsidiary Directive (2011/96) and considers the implications of double non-taxation.
 
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