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Italian Court of Cassation holds reduced dividend withholding tax is applicable on distributions to foreign pension funds

|Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties|Italy, European Union
Italy, European Union

Executive summary

By judgment No. 1967/2020,1 recently made broadly available to the general public by local reporting, the Italian Court of Cassation (CC) affirmed that the reduced 1.65% dividend withholding tax (WHT) set forth under article 27, paragraph 3-ter, of Presidential Decree No. 600 of 29 September 1973 (the Decree), is applicable to a Spanish management company that in 2006 received dividend distributions from Italian resident entities on behalf of 11 Spanish …

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