On 10 July 2020, the Italian Supreme Court published the decision no. 14756, which interprets the beneficial ownership requirement under the Interest and Royal Directive by making reference to the judgement of the Court of Justice of the European Union on the Danish cases.
In the context of a merger leverage buyout transaction, an Italian company paid interest to its Luxembourg shareholder, which carried on financial and treasury activities, applying the withholding tax exemption under the IRD.
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