Article 27-bis of Presidential Decree no. 600/1973

Late-issued certificates and the Parent-Subsidiary exemption: the Italian Supreme Court confirms a substance-over-form approach

by A&P, Matteo Aicardi | 21 May, 2026 | Publications

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...

Late-issued certificates and the Parent-Subsidiary exemption: the Italian Supreme Court confirms a substance-over-form approach

Articoli recenti