Requirements for withholding tax exemption for interest and royalties paid to EU associated companies clarified

In a tax ruling dated 27 May 2009, No. 131/E, the Italian Tax Administration (ITA) clarified that the exemption from withholding tax provided for interest and royalties paid to associated companies resident in a EU Member state does not apply if the recipient holds the company that makes the payment through a related company (i.e. indirect holding). The ITA further clarified that in order to benefit from the exemption, the participation in the associated company must be maintain…