COMMENTS REGARDING COMPATIBILITY WITH THE ANTI-TAX EVASION LAW CONCERNING “REPURCHASE – REPO – AGREEMENTS” AND “LOANS” HAVING AS OBJECT DIVIDENDS WITH THE EU PRINCIPLE OF FREE MOVEMENT OF CAPITAL.
Summary: 1: Foreword – 2. Important contractual arrangements– 3. The tax treatment of profits deriving from securities that are object of repurchase agreements – 4. Development of regulation – 5. Purposes of the law – 6. Application of the law for non – resident subjects – 7. Free movement of capital – 8. Conclusions.
The article is by Francesco Capitta, Tax partner of Macchi di Cellere Gangemi.