Tax treatment of dividends distributed to non-resident tax-transparent entities

In Ministerial Ruling 17/E of 27 January 2006 (the Ruling), the Italian tax authorities analysed the tax regime applicable to dividends payable to a non-resident entity which is deemed to be tax transparent in its country of establishment. This Ruling deals in particular with the potential application of the provisions of the income tax treaties to such a scenario. This article analyses background, content, impact and consequences of the Ruling and provides an in-depth and authoritative overview of the treatment, under Italian tax law, of dividends paid to non-resident transparent entities.