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Italy Clarifies Transparent Entity's Eligibility for Reduced Dividend Withholding for Pension Funds and Tax Treaty Rates

|Approved Changes|Italy
Italy

The Italian Tax Authority has issued Ruling No. 156 of 28 May 2020 concerning whether dividend payments made to a transparent entity (an Authorized Contractual Scheme - ACS) holding/managing investments for UK pension funds can qualify for beneficial dividend withholding tax treatment in Italy, including:

  • the 11% rate for Italian source dividends paid to pension funds established in EU/EEA Me…

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