The article critically discusses a recent tax decision of the Italian Supreme Court, according to which the application of the withholding tax exemption on dividends distributed by Italian Subsidiaries to Parents of other Member States (which is demanded by article 5 of the Parent-Subsidiary Directive) is subject to the effective taxation of such dividends in the latter Member States.
Arginelli, P., Tenore, M., No withholding tax exemption. Effective taxation of dividends. Parent-Subsidiary Directive. Italian Supreme Court, <<HIGHLIGHTS & INSIGHTS ON EUROPEAN TAXATION>>, 2019; 2019 (3): 9-15 [http://hdl.handle.net/10807/144379]
No withholding tax exemption. Effective taxation of dividends. Parent-Subsidiary Directive. Italian Supreme Court
Arginelli, Paolo;
2019
Abstract
The article critically discusses a recent tax decision of the Italian Supreme Court, according to which the application of the withholding tax exemption on dividends distributed by Italian Subsidiaries to Parents of other Member States (which is demanded by article 5 of the Parent-Subsidiary Directive) is subject to the effective taxation of such dividends in the latter Member States.
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