Italian Budget Law for 2021, UCITS and Refund Requests: Is There a Light at the End of the Tunnel?

The Budget Law for 2021 amends the Italian tax regime applicable to EU/EEA UCITS, which was unfavourable in comparison to the rules applicable to domestic UCITS. Concerns remain, however, regarding the retroactive application of the rules, as well as the path to be followed by taxpayers who want to submit a refund request. This note seeks to address these questions and provide useful guidance for foreign taxpayers.