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Italy Clarifies Treaty Benefits for Participants in Transparent Swiss Fund

|Treaty Development|Italy-Switzerland
Italy-Switzerland

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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