The Italian Revenue Agency (IRA) has published Ruling No. 258 of 19 April 2021 concerning withholding tax on dividends paid by Italian companies to a fiscally transparent fund (Fond Commun de Placement - FCP) in Switzerland that includes a Swiss private law foundation as a participant. The ruling provides that as a fiscally transparent entity, the FCP does not qualify as a resident of Switzerland for the purpose of the 1976 Italy-Swiss tax treaty and is not eligible for the treaty withholdin…