Luxembourg:
The 2021 Draft Italian Budget Law
18 November 2020
Arendt & Medernach
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The 2021 draft Italian budget law provides for new interesting
tax measures applicable from 1st
of January 2021 that will undoubtedly enhance
investments in Italian companies by European investment funds.
In particular, Luxembourg-based UCITs and AIFs managed by a
regulated AIFM will benefit from full Italian
tax-exemption on dividends received from and
capital gains realised on their Italian shareholding
(similar measures being already applicable to certain Italian
outbound interest payments).
These new measures aim to put EU / EEA investments funds
allowing an adequate exchange of information and Italian investment
funds on the same tax footing, in line with a number of judgments
rendered by the CJEU over the last decade on dividend payments and
with the recent action launched by the EU Commission against France
on capital gain taxation.
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