Italy Tax Agency Clarifies Application of Withholding Tax Exemption Regime to Dividends Paid to Parent Company

The Italian Revenue Agency Feb. 25 issued Letter No. 48/2025, clarifying the exemption from withholding tax for dividends paid to a parent company. The taxpayer, a company under the collaborative compliance regime, sought to apply the withholding tax exemption regime under Article 27bis of Presidential No. Decree 600/1973, to dividends it would distribute to its Netherlands parent. The taxpayer sought clarification as to whether the withholding tax exemption regime would apply, even if the parent wouldn’t have met the one-year shareholding requirement under the decree at the time of the distribution. The Tax Agency clarified that: 1) the collaborative compliance ...