Clifford Chance

Securing the WHT exemption on Italian bonds in practice

3 September 2020

1. Under Italian law ("Decree 239/1996") interest, premium and other income (including the difference between the redemption amount and the issue price) (hereinafter collectively referred to as "Interest") from Italian Bonds are subject to a 26% substitute tax when received by, among others, non-Italian resident persons not acting through a permanent establishment in Italy.

2. The substitute tax applies not only upon payment of the coupon, but also upon redemption and transfer of the Bonds.

3. The substitute tax is applied by the Italian bank or other financial intermediary, or Italian permanent establishment of a foreign bank or financial intermediary, that intervenes in the payment of the relevant income.

Download PDF