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in via di mero accertamento
a chi osa insieme
Nov 3, 2010 16:10
13 yrs ago
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Italian term

dividendi esclusi

Italian to English Law/Patents Finance (general) Taxation
The Agenzia Entrate is notifying a company that during an audit it has acertained "Operazione che hanno generato dividendi esclusi di fonte italiana or estera".

What does "esclusi" mean in this case. It cannot mean excluded. Might it mean without gross dividends without taxes being withheld?
Proposed translations (English)
4 non eligible dividends
References
Esclusi

Discussion

Howard Sugar (asker) Nov 8, 2010:
What is meant here is that there is a parent company in France and a subsidiary in Italy. There is a different taxation of dividend (as income) for domestic and foreign companies . The two companies sold each other futures on a basket of shares in order to produce a paper loss in one country (tax shelter) and a gain in another country with lower taxation. The only purpose being to pay less taxes. Hence the dividends have been excluded from the income declarations in Italy which is illegal.
James (Jim) Davis Nov 3, 2010:
Need more context please

Proposed translations

2 mins

non eligible dividends

Declined
What it is not eligible for should be clear from the context.
Something went wrong...

Reference comments

6 hrs
Reference:

Esclusi

It basically means exempt from withholding tax. However, the Italian tax authorities have used the word "esclusi" to really define a particular class of exemption. These dividends are excluded to prevent double taxation. When it gets this complex, a literal "excluded" tran with the inverted commas is probably best.

http://www.tributimpresa.it/html/documenti/dottrina/Art_Tesa...
Peer comments on this reference comment:
agree Mr Murray (X) : This is what makes it difficult to translate. I like the solution of using apostrophes (I use single ones when setting off 'unusual' words, but whatever). Otherwise, you'd have to include this explanation as a footnote.
18 mins
Standard practice for ICs is to put singles inside doubles or vice versa whichever you prefer.
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