New Italy-China Double Taxation Agreement soon in force

New Italy-China Double Taxation Agreement soon in force

On 5 November 2024, the Italian Chamber of Deputies approved the bill for the ratification and execution of the Double Taxation Agreement (DTA) signed in 2019 between the governments of the Italian Republic and the People’s Republic of China regarding income taxes double taxation and the prevention of tax evasion and avoidance. With the Meloni government taking office in October 2022, the bill had to obtain a new approval by the Italian Council of Ministers, and subsequently underwent Parliament discussion. The Agreement will enter into force following the exchange of ratification instruments between the contracting countries, expected by 1 January 2025.

The 2019 Agreement updates the previous DTA signed on 31 October 1986, adapting the latter to the OECD/G20 BEPS Project.

Among the revisions, Article 10 provides for a reduced withholding tax rate from 10% to 5% in relation to dividends from investments participated for at least 25% of the capital, and continuously for 365 days.

Article 11 regulates interests, providing for a reduction to 8% for interests paid to financial institutions for 3 years minimum duration loans aimed at investment projects.

Finally, Article 12 confirms a standard rate at 10% for royalties, with a reduction to 5% for royalties on industrial, commercial or scientific equipment.