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An analysis by Alma LED, Taxand Italy
The Italian Supreme Court recently handed down a landmark decision (Judgment 20 February 2025 no. 4427), ruling that the domestic WHT exemption on outbound interest payments made by Italian resident enterprises to foreign institutional investors applies also in case of indirect financing (i.e., where the foreign institutional investor, such as a foreign investment fund, is the beneficial owner of the interest but not the direct recipient of the interest payment).
Francesco Cardone from Alma LED, Taxand Italy, has provided a more detailed analysis of this decision, which facilitates cash repatriation for foreign investment funds and may have broader implications for dividend WHT exemptions under EU and international tax principles.
You can read the full analysis here.
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