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| Author: | Fantozzi, F. |
| Title: | Italy: Dividend washing and usufruct of shares in the light of the lack of a general anti-abuse clause |
| Journal: | European Taxation
1994 : VOL. 34:12, p. 452-456 |
| Index terms: | DOUBLE TAXATION ITALY INVESTMENT TAX |
| Language: | eng |
| Abstract: | Italian domestic tax law provides full elimination of economic double taxation on dividends through an imputation credit system. In a cross-border situation double taxation is reduced through a partial participation exemption. The article analyses the functioning and the tax implications of dividend washing and usufruct of shares, particularly to the standpoint of the tax authorities, in order to demonstrate the legality of such schemes before and after Decree-Law 372. |
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