The Italian Supreme Court issued a ruling in May 2016 concerning whether a UK company qualified as the beneficial owner of dividends to receive the benefit of the Italy-UK tax treaty. The UK Company is part of a group ultimately owned or controlled by a U.S. corporation. In 2001 and 2002, the UK company received dividends from an Italian subsidiary (99.83% holding), which at the time withheld 27% tax on the dividend payments. The UK company then applied for a refund based on the 5% withholding tax rate under the tax treaty, which is available if the beneficial owner is...