Italy Tax Agency Clarifies Withholding Taxes on Dividends

The Italian Revenue Agency June 23 issued Letter No. 338/2022 clarifying withholding taxes on dividends. The taxpayer is a Netherlands based pension fund entity that outsources, to its subsidiaries, the administration of pensions and asset management. The taxpayer pays 1.2 percent Italian withholding tax, as a resident company subject to corporate income tax in its home country, on dividends received from its subsidiaries. The taxpayer sought clarification as to whether it was, instead, required to pay the 11 percent corporate withholding tax under the Italian tax regime. The tax agency clarified that the taxpayer: 1) is established in an EU ...