The Italian Revenue Agency has published Ruling No. 380 of 11 September 2019 concerning Italy's withholding tax exemption on dividends paid by a subsidiary to its parent in a case where the parent has relocated its headquarters from Luxembourg to Switzerland and, under the domestic laws of both countries, the transfer takes place in legal continuity. In Luxembourg, the parent's business registration is canceled, without liquidation or dissolution, and in Switzerland, the parent is registered…