Beneficial owners recognised for tax purposes in Italy - Italian equities

04.07.2017

The following types of beneficial owner of Italian equities are recognised for tax purposes in Italy:

  • Residents of a Double Taxation Treaty (DTT) country;
  • EU/EEA corporations;
  • EU/EEA pension funds;
  • Supranational organisations recognised as such by Italian law.

Residents of a Double Taxation Treaty (DTT) country

Relief at source is available to a beneficial owner that qualifies for the benefit of a reduced rate of withholding tax in accordance with a DTT between its country of residence and Italy. The maximum rate of withholding tax is defined in the relevant DTT.

If the beneficial owner did not obtain relief at source, a reclaim of the relevant amount of withholding tax is available through Clearstream Banking by means of a quick refund or a standard refund.

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

EU/EEA corporations

Relief at source is available at 1.375%/ 1.20%1to a beneficial owner that is:

  • Incorporated as an entity; and
  • Subject to corporate income tax in its country of residency; and
  • Resident in the European Union or European Economic Area (EU/EEA); that is, listed in the Italian White List currently in force.

If the beneficial owner did not obtain relief at source, a reclaim of the relevant amount of withholding tax is available through Clearstream Banking by means of a quick refund or a standard refund.

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

EU/EEA pension funds

Relief at source is available at 11% to a beneficial owner that is:

  • An entity that is established as a pension fund; and
  • Resident for tax purposes in an EU/EEA country included in the White List.

If the beneficial owner did not obtain relief at source, a reclaim of the relevant amount of withholding tax is available through Clearstream Banking by means of a quick refund or a standard refund.

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

Supranational organisations

Exemption at source is available to a beneficial owner that is a supranational organisation recognised as such by Italian law.

A full reclaim of withholding tax is available through Clearstream Banking if the beneficial owner, being a supranational organisation recognised as such by Italian law, has not obtained an exemption at source.

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

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1. 1.375% until 31 December 2016, 1.20% as of 1 January 2017.