Italian Supreme Court order no. 13128/2026 clarifies that the late receipt of a certificate issued by the foreign tax authority does not preclude the withholding tax exemption on EU dividends under Article 27-bis of Presidential Decree no. 600/1973, provided that the substantive requirements were met at the time of the distribution. The documentary deadline is therefore not a constitutive condition for the exemption, but a safeguard for the distributing company when deciding not to apply withholding tax.
Published in La Circolare Tributaria no. 22-23/2026 by Euroconference.
