Italy Supreme Confirms Legal and Economic Control of Dividend Income Required for Rate Benefit under Tax Treaty
The Italian Supreme Court issued a ruling in May 2016 concerning whether a UK company qualified as the beneficial owner of dividends to receive the benefit of the Italy-UK tax treaty. The UK Company is part of a group ultimately owned or controlled by a U.S. corporation. In 2001 and 2002, the UK company received dividends from an Italian subsidiary (99.83% holding), which at the time withheld 2…
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