Resumen de Participants in foreign transparent entity denied treaty benefits (the good, the bad and the ugly)
The author considers the practical consequences of and, more importantly, the reasoning behind, Ruling 17/E of 27 January 2006, which states that foreign pension funds that participate in an Irish Common Contractual Fund (CCF) are not entitled to the benefits of the tax treaty between their State of establishment and Italy in respect of CCF income.
