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Private equity and beneficial ownership: will the Italian Supreme Court confirm a look-through approach?

On 3 February 2022, the Second-Degree Tax Court of Milan issued a decision on a case dealing with interest payments by an Italian company to its Luxembourg parent company in the context of a foreign investment fund structure. In particular, the Second-Degree Court ruled that (i) the WHT exemption granted by the Interest and Royalty […]

Contributed by ALMA LED

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