Italian Tax Authorities Provide First Clarification of the New Tax Exemption for Dividends Related to Direct Investment by EU/EEA Investment Funds

Abstract

In this note, the authors discuss Answer 327/2021 of the Italian tax authorities, which addresses the new tax exemption for dividends on qualified shareholdings in relation to investments in companies resident in Italy for tax purposes. The Answer addresses foreign undertakings for collective investment established in an EU Member State or EEA country that exchanges adequate information with Italy, in particular, where the managers are subject to the EU Alternative Investment Fund Managers Directive (2011/61) rather than the EU UCITS Directive (2009/65).