Italy: Non-resident holding company, “beneficial owner” of dividends from Italian subsidiary

Italy: “Beneficial owner” of dividends from subsidiary

A decision of the Italian Supreme Court sets out guidance on the criteria to be considered when deciding whether a non-resident holding company qualifies as the “beneficial owner” of dividends distributed by an Italian subsidiary.

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The high court held that the lack of an organizational structure and employees, coupled with limited operating costs and receivables, does not in itself prevent a holding or sub-holding company from qualifying as the “beneficial owner” of dividends for income tax treaty purposes.

 

Read a March 2017 report [PDF 172 KB] prepared by the KPMG member firm in Italy

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