The Orbitax Global Minimum Tax Solution now supports the generation of the Belgium P2 Notification Form in XML format. Find out more or book a demo.
Italy: Supreme Court rules Subject-to-Tax Test does not require actual payment of tax in Switzerland; grants full relief from withholding tax on royalties paid to qualifying Swiss recipient. — Orbitax Expert Corner
Italy: Supreme Court rules Subject-to-Tax Test does not require actual payment of tax in Switzerland; grants full relief from withholding tax on royalties paid to qualifying Swiss recipient.
The case and the decision
On 6 June 2023, the Italian Supreme Court decided the case of a Swiss-resident company seeking the refund of the Itali...
CountryItaly-Switzerland- Author(s)Carlo Romano, partner and leader of tax controversy and dispute resolution at PwC TLS Avvocati e Commercialisti.Daniele Conti, senior manager and lawyer at PwC TLS Avvocati e Commercialisti.
- Updated5 July 2023
- More from Orbitax
- Tax News & Alerts
- Expert Corner
- Corporate Tax Rates
- Withholding Tax Rates
- Tax Treaties
- Country Chapters
- Pillar 2 - Country Analysis