Italy Clarifies Transparent Entity's Eligibility for Reduced Dividend Withholding for Pension Funds and Tax Treaty Rates

The Italian Tax Authority has issued Ruling No. 156 of 28 May 2020 concerning whether dividend payments made to a transparent entity (an Authorized Contractual Scheme - ACS) holding/managing investments for UK pension funds can qualify for beneficial dividend withholding tax treatment in Italy, including:

• the 11% rate for Italian source dividends paid to pension funds established in EU/EEA Member States (until the transitional period ends for the UK's exit from the EU); and
• the 15% rate un…