Dividend flows : treaty rules or the Parent-Subsidiary Directive? The Italy-UK experience

Analyses a specific provision in the Italy-United Kingdom tax treaty concerning dividends and the interaction of the provision with the domestic tax systems of Italy and the United Kingdom. The discussion focuses on the application of Art. 10 (Dividends) of the treaty and the tax credits granted to Italian resident shareholders of UK companies and vice versa. The article also considers the provisions of the EU Parent-Subsidiary Directive regarding dividend distributions which apply in both countries.