Italian Court of Cassation endorses withholding tax exemption for interest from indirect financing

11 July 2025|Tax Alerts, Legislation & Policy, National/Federal Taxation, Global|Italy

The Supreme Court of Cassation, in February 2025, ruled in favor of a "look-through" approach to allow a beneficial owner to claim the withholding tax exemption on interest on medium- to long-term loans (granted under Article 26 para 5-bis of Italian Presidential Decree No. 600/1973) by bypassing interposing entities.
This ruling affects foreign institutional investors involved in indirect financing.
Affected nonresident lenders may want to consider the appropriate steps for requesting refunds of …

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