by A&P, Fabrizio Ricci | 2 Jul, 2026 | Publications
The Advocate General’s Opinion in Case C-241/25 confirms the Court of Justice of the European Union’s case law holding that a definitive withholding tax on dividends paid to loss-making non-resident companies is incompatible with the free movement of capital where the...
by A&P, Matteo Aicardi, Fabrizio Ricci | 28 May, 2026 | Publications
A contribution published in IPSOA Quotidiano examines Italian Revenue Agency Ruling No. 90/2026, which for the first time addresses the tax treatment of profit distributions made on a basis that is disproportionate to shareholders’ equity interests. According to...
