New Withholding Taxes on Interest Paid to Non-Resident Entities: Beneficial Ownership Requirement as a Shield against Conduit Structures

Journal
Labombarda, G.; Bitetti, G.
Italy
European Taxation 2012 (Volume 52), No. 1
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article discusses a new provision that imposes a withholding tax of 5% on interest payments that meet all of the requirements for benefitting from the EU Interest and Royalties Directive except for the condition regarding beneficial ownership.