The Italian Supreme Court’s Decision in the ITW Case: The Beneficial Ownership Requirement and Double Non-Taxation

Journal
European Union; Italy; OECD; United States
Bulletin for International Taxation 2019 (Volume 73), No. 9
The author, in this article, considers the decision of the Italian Corte Suprema di Cassazione (Supreme Court) in the recent case of ITW regarding treaty benefits, in particular, with regard to the issues of beneficial ownership and double non-taxation.