Turin Tax Court Denies Treaty Residence State Dividend Exemption Absent Source Taxation

Journal
Author
Tripoli, P.F.
Country
Italy
Published Date
Issue
European Taxation 2011 (Volume 51), No. 6
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This article discusses a recent decision of the Turin Tax Court wherein the Court ruled that an Italian taxpayer shall not benefit from a full corporate tax exemption on dividends received from a German subsidiary despite the tax treaty provision that exempted the dividends from residence taxation due to the fact that no source taxation was levied in Germany.