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.