Financial Services Tax Insider No. 1/2019
Interest paid by Italian SICAFs to foreign qualified lenders do not benefit from the WHT exemption regime provided for by Art. 26(5 bis) of Presidential Decree N. 600/1973
On April 5th, 2019 the Italian Tax Authority published the answer to the ruling n. 98 that clarifies that the withholding tax exemption provided for by Art. 26, par. 5 bis, Presidential Decree n. 600/1973 does not apply on interest paid by an Italian real estate fixed capital investment company (“SICAF”) to European lenders.