Outbound dividend distribution from an Italian company to a Swiss company

The dividend distribution by an Italian company to a Swiss shareholder is a transaction that triggers a number of tax ramifications that should be duly considered, in particular with reference to the application of the Italian withholding tax, the responsibility in the application of which lies in the hands of the Italian distributing entity. Favorable conditions could be reached under the application of the Italy-Switzerland Double Tax Treaty or of the EU-Switzerland Agreement, provided that specific subjective conditions are met and that the antiabuse rules are respected. This article intends to go through the main Italian tax rules applicable to the transaction, also in light of the latest Swiss developments.