16 February 2017 Italian Supreme Court issues important guidance on beneficial ownership conditions for pure holding companies Italy's Supreme Court issued Decision n. 27113 (the Decision) on December 28, 2016, on the concept of beneficial ownership in the context of dividends received by a holding company under the France-Italy income tax treaty. The Supreme Court held that the status of beneficial owner is ultimately to be determined, as a matter of fact, based on the particular nature of the recipient holding company and the functions typically performed in its operations. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2017-0320 |
