An analysis by LED Taxand
On 3 February 2022, the Second-Degree Tax Court of Milan issued a decision on a case dealing with interest payments by an Italian company to its Luxembourg parent company in the context of a foreign investment fund structure.
If the look-through approach applied by the Second-Degree Court is confirmed by the Supreme Court, this could grant the WHT exemption on interests paid by an Italian company also in case of private equity or real estate fund structures, where the beneficial owner or the foreign qualifying fund are not the direct recipients of the interests.
Our Italian firm, LED Taxand, examines the implications, read the full article here.
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