The contribution concern the possible application of article 10 of the Italy-Japan Income Tax Treaty (1969)[1] to dividends paid by an Italian-resident company to certain US special purpose vehicles acting on behalf of a Japanese pension fund. In particular, the Italian Supreme Court had to deal with the issue of whether those dividends could be regarded as “received” by the Japanese pension fund for the purpose of the application of article 10 of the treaty, which is drafted along the lines of the OECD Model Tax Convention (OECD Model) (1963)[2] and, therefore, does not include any reference to the “beneficial owner” of the dividends.

Arginelli, P., Maisto, G., Italy: Applicability of Article 10 of the Italy-Japan Income Tax Treaty to Italian-Source Dividends Paid to a Japanese Pension Fund through Certain US Limited Partnerships, in Eric Kemmeren, P. E., Tax Treaty Case Law around the Globe 2020, IBFD, Amsterdam 2021 <<Tax Treaty Case Law Series>>, 2020: 151-162 [https://hdl.handle.net/10807/222937]

Italy: Applicability of Article 10 of the Italy-Japan Income Tax Treaty to Italian-Source Dividends Paid to a Japanese Pension Fund through Certain US Limited Partnerships

Arginelli, Paolo
Co-primo
;
Maisto, Guglielmo
Co-primo
2021

Abstract

The contribution concern the possible application of article 10 of the Italy-Japan Income Tax Treaty (1969)[1] to dividends paid by an Italian-resident company to certain US special purpose vehicles acting on behalf of a Japanese pension fund. In particular, the Italian Supreme Court had to deal with the issue of whether those dividends could be regarded as “received” by the Japanese pension fund for the purpose of the application of article 10 of the treaty, which is drafted along the lines of the OECD Model Tax Convention (OECD Model) (1963)[2] and, therefore, does not include any reference to the “beneficial owner” of the dividends.
Inglese
9789087227111
IBFD
2020
Arginelli, P., Maisto, G., Italy: Applicability of Article 10 of the Italy-Japan Income Tax Treaty to Italian-Source Dividends Paid to a Japanese Pension Fund through Certain US Limited Partnerships, in Eric Kemmeren, P. E., Tax Treaty Case Law around the Globe 2020, IBFD, Amsterdam 2021 <<Tax Treaty Case Law Series>>, 2020: 151-162 [https://hdl.handle.net/10807/222937]
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Utilizza questo identificativo per citare o creare un link a questo documento: https://hdl.handle.net/10807/222937
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