A new article of Mr. Alberto Trabucchi about taxation of inbound dividends – after the adoption in Italy of the ATAD Directives – is published on Rivista della Guardia di Finanza no 2/2019.

The recent legislative decree no. 142 of 21 November 2018 has implemented the above-mentioned Directives, updating the national Controlled Foreign Companies rules. Due to this change also the domestic rules governing the taxation in Italy of the so called “black-dividends” has been duly updated.

In this article, Mr. Alberto Trabucchi analyses the current tax legislation on dividends arising from a tax haven, with a particular focus on the control thresholds and the exemption/business test that need to be satisfied for exclusion.

http://www.gdf.gov.it/ente-editoriale-per-la-guardia-di-finanza/pubblicazioni/rivista-della-guardia-di-finanza/archivio/anno-2019/mar-apr/versione-new.pdf/at_download/file