Italy Allows Withholding Tax Exemption on Dividends Paid to Swiss Parent Following Repeal of Swiss Preferential Regime for Holding Companies

The Italian Revenue Agency (IRA) has published Ruling No. 135 of 2 March 2021 concerning the application of withholding tax on dividend paid to a Swiss parent company, which is qualified as a holding company. In particular, the ruling answers the question of whether Article 9 of the 2004 agreement between the European Community and the Swiss Confederation may be applied to exempt dividends paid by an Italian company to its Swiss parent considering changes in the Swiss tax system with effect …