02 March 2018 Italian Tax Authorities clarify requirements to benefit from reduced treaty rate on dividends under Italy-US treaty The Italian Tax Authorities (IRA) issued a response to a private tax ruling request concerning the process available to a United States (US) investor to benefit from relief at source from the reduced treaty rate of 5% on Italian source dividends, as provided for by Article 10 paragraph 2, letter (a) of the Italy-US Tax Treaty (the Treaty). The ruling applicant (i.e., a US corporation, principal investment firm) was a shareholder of an Italian asset management company, holding 35% of its share capital and entitled to treaty benefits. Document ID: 2018-0477 |
