Executive summaryOn 28 May 2020, the Italian Revenue Agency (ITA) published Ruling No. 156, which addresses the tax treatment of Italian source dividends paid to an Authorized Contractual Scheme (ACS) established by a pool of United Kingdom (UK) pension funds.The ITA clarified that no look-through approach can be applied with respect to the Italian 11% withholding tax (WHT) rate that Article 27(3) of Italian Presidential Decree No. 600 of 29 September 1973, (the Decree), provides for European Union (EU)/European Economic Area (EEA) pension funds receiving Italian source dividends.Consequently, the ITA stated that:The ACS is not entitled to the reduced 11% WHT rate, because it...