Newsalert | Tax 04/03/2025

In its decision no. 4427 of 20 February 2025, the Italian Supreme Court ruled that in cases of indirect financing, the application of the exemption from WHT under Article 26(5-bis) of D.P.R. No. 600/1973 must be assessed at the level of the beneficial owner, following the look-through approach. 

In the latest newsalert, Chiomenti's Professionals analyzed the ruling, which overturns the Italian tax authorities' position focused on the direct recipient.