No withholding tax exemption. Effective taxation of dividends. Parent-Subsidiary Directive. Italian Supreme Court

Paolo Arginelli; M. Tenore

No withholding tax exemption. Effective taxation of dividends. Parent-Subsidiary Directive. Italian Supreme Court

Paolo Arginelli
, M. Tenore

Università Cattolica del Sacro Cuore

Research output: Contribution to journal › Article

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.

Original language	English
Pages (from-to)	9-15
Number of pages	7
Journal	HIGHLIGHTS & INSIGHTS ON EUROPEAN TAXATION
Volume	2019
Publication status	Published - 2019

Keywords

taxation of dividends

Cite this

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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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AB - 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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ER -

No withholding tax exemption. Effective taxation of dividends. Parent-Subsidiary Directive. Italian Supreme Court

Abstract

Keywords

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