by A&P, Matteo Aicardi | 9 Jul, 2026 | Publications
Decision no. 1434/2026 of the Milan First-Instance Tax Court addresses the low-tax jurisdiction requirement for the participation exemption in relation to a capital gain realised upon the liquidation of a foreign subsidiary. The court held that the criteria set out in...
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 | 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...
