Newsletter - The Tax Court of Milan holds that the exemption from WHTs on interest paid to non-Italian institutional investors is applicable on a “look-through” basis

Newsletter - The Tax Court of Milan holds that the exemption from WHTs on interest paid to non-Italian institutional investors is applicable on a “look-through” basis

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In Decision No. 4708 of 11 November 2019 (the “Decision”), Tax Court of first instance of Milan (“TC of Milan”) upheld the applicability on a “look-through” basis of the domestic exemption from withholding taxes on interest payments related to mid-long term financings under Art. 26, para. 5-bis, of the Presidential Decree 29 September 1973, No. 600 (“Art. 26, para. 5-bis”).

The Decision is important because delivered in the context of a wider audit activity currently carried out by the Italian Revenue Agency (“IRA”).


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