Ruling on application of EC Parent-Subsidiary Directive to trust companies

In Ruling No. 37/E of 13 March 2006, the Italian tax authorities clarified that dividends paid by an Italian company to its qualifying EU parent company are exempt from Italian withholding tax even if the shares in the Italian subsidiary company are held through an Italian trust company (Società fiduciaria). To qualify for the exemption, the trust company must comply with all the formal requirements under Italian law, e.g. attestations. Details of the ruling are summarized below…