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HMRC internal manual

Double Taxation Relief Manual

Italy: Interest and Royalties

The agreement allows for source state taxation on interest and royalties. However, the EC Directive on Interest and Royalties (2003/49EC) (see INTM400000) provides for the abolition of source state taxation on interest and royalty payments made between associated companies in different Member States. It also ensures that the payments are subject to tax once in a Member State. It applies in the United Kingdom with effect from 1 January 2004.