Article 8 OECD Model Convention (shipping, inland waterways transport and air transport) constitutes a lex specialis which applies in lieu of the
possible theses which could challenge the total exemption in Italy of the dividends distribuited by the German subsidiary: a) the Italian tax
, the article provides an overview on the complex legal framework, which regulates the sector at the moment, in order to estimate its pro-competitive
Italian companies able to exploit them. The complementary two thirds do have them, according to the members of the research projects, which shows