The Italian Revenue Agency has published Ruling No. 537 of 6 August 2021 concerning the correct interpretation of Article 9 (formally Article 15) of the 2004 agreement between the European Community and the Swiss Confederation, which provides a withholding tax exemption on dividends if certain conditions are met. In particular, the ruling answers the question of whether dividends distributed by an Italian company, wholly owned by the Swiss parent company since 1 August 2020, can qualify for …