The first important step to facilitate the issue of bonds by Italian corporations with subsequent investment from non - resident investors was made in 1996 through Law 239. The application of Law 239 was originally restricted to bonds issued by banks and listed companies and provided for a withholding tax exemption on interest paid to certain non - resident investors. The sole criteria for benefitting from the exemption was that such non - resident investors, who had to be the beneficial owners of the bond, were resident in white list countries (i.e. countries who had a Double Tax Treaty in force with Italy which provided for an exchange of information). Law 239 contained no restrictions on the nature of the foreign investor: it could be an individual, a non-profit organization, a partnership or a corporate entity.