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Company in Italian Compliance Program May Apply Dividend Withholding Exemption Under EU-Swiss Agreement before Holding Period Condition is Met

|Approved Changes|Italy-Switzerland
Italy-Switzerland

The Italian Revenue Agency has published Ruling No. 537 of 6 August 2021 concerning the correct interpretation of Article 9 (formally Article 15) of the 2004 agreement between the European Community and the Swiss Confederation, which provides a withholding tax exemption on dividends if certain conditions are met. In particular, the ruling answers the question of whether dividends distributed b…

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