Italy Tax Agency Issues Circular on Treatment of Nonresident Capital Gains From Qualified Share Sales

The Italian Revenue Agency July 29 issued Circular No. 17/E, clarifying for local tax offices the tax regime for capital gains from qualified shareholdings realized by nonresident companies and commercial entities, following changes enacted by Law No. 213/2023, the 2024-2026 Budget Law. The circular explains that: 1) a special regime applies, subject to conditions, to capital gains realized by nonresident companies and commercial entities that lack permanent establishment (PE) in Italy, and that are resident in the EU or EEA and subject to corporate income tax there, from sales of qualified shareholdings fiscally relevant in Italy; 2) amendments to Article ...