Italy Clarifies Treaty Benefits for Participants in Transparent Swiss Fund

The Italian Revenue Agency (IRA) has published Ruling No. 258 of 19 April 2021 concerning withholding tax on dividends paid by Italian companies to a fiscally transparent fund (Fond Commun de Placement - FCP) in Switzerland that includes a Swiss private law foundation as a participant. The ruling provides that as a fiscally transparent entity, the FCP does not qualify as a resident of Switzerl…
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