Marina Lombardo

The Italian tax authorities have recently ruled that the domestic WHT exemption granted to certain foreign investment funds and other qualified investors on interest deriving from medium / long term loans is not applicable to interests paid through an intermediate entity, thus rejecting a “look through” approach.

In Italy, new rules came into force regarding the structure, content and submission of the transfer pricing documentation. These changes apply to both the master file and the local file and have significant implications for the taxpayer.

Following the 2021 Italian Budget Law, dividends and capital gains deriving by certain foreign EU/EEA UCIs are not subject to Italian taxation, either by way of WHT or substitute tax, starting from January 1, 2021.