HMRC internal manual

Double Taxation Relief Manual

Italy: Treaty summary

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Italy are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on

Subject Comments Article
Portfolio dividends 15% 10
Dividends on direct investments 5% 10
Conditions for lower rate on dividends on direct investments The beneficial owner must be a company which controls, directly or indirectly, at least 10% of the voting power of the payer 10
Property income dividends 15% 10
Interest 10% (Note 1) 11
Royalties 8% 12
Government pensions Taxable only in Italy unless the individual is a resident and national of the UK. See also the entry on Notes page in respect of government service. 19
Other pensions/annuities Taxable only in the UK 18
Arbitration No N/A



Note 1: Interest paid in the following circumstances is taxable only in the state of residence of the beneficial owner of the interest:

  • the payer is the Government of Italy, a political subdivision or local authority thereof
  • the interest is paid in consideration of a loan made, guaranteed or insured by the UK (including the Export Credits Guarantee Department) or one of its local authorities or public establishments