EYItalian Tax Authorities provide clarifications on Brexit impact on Italian source taxation and application of look-through approach to outbound dividends paid to ACS
|Tax Alerts, Legislation & Policy, Na ...|Italy, United Kingdom, European Union
Executive summary
On 28 May 2020, the Italian Revenue Agency (ITA) published Ruling No. 156, which addresses the tax treatment of Italian source dividends paid to an Authorized Contractual Scheme (ACS) established by a pool of United Kingdom (UK) pension funds.
The ITA clarified that no look-through approach can be applied with respect to the Italian 11% withholding tax (WHT) rate that Article&…
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