In the Decree-law for the Restoration of the Public Debt No. 323 dated June 20 1996, as amended on July 11 1996, (the Decree-law), the Italian government introduced the principle that any payment of capital income made from Italy by an Italian company (other than a bank) to a foreign financial institution is subject to a flat rate withholding tax of 15% if made to a foreign bank and to a withholding of 15% on account of taxes if made to foreign branches of Italian banks. The withholding of the 15% will apply to payments made to foreign branches of Italian banks even where the branch has not arranged for its funding from other banks.
July 31 1996