Key facts
| Recipient of the Italian dividend | Withholding |
|---|---|
| Non-resident - general rate | 26% |
| EU/EEA company subject to corporate tax | 1.2% |
| EU parent, ≥10% held for a year (PSD) | 0% |
| Resident individual | 26% final |
| Resident company | 95% exempt → ≈1.2% effective |
Why 1.2% exactly
The number is not a concession - it is equal treatment. An Italian company receiving dividends from another Italian company includes only 5% of them in taxable income; at the 24% IRES rate that is an effective 1.2%. After EU case law on the free movement of capital, Italy extended the same effective burden to corporate shareholders in the EU and EEA: charging a foreign company 26% where a domestic one pays 1.2% was not defensible.[1][2]
When it matters
Related companies with a 10% stake held for a year already get 0% under the Parent–Subsidiary Directive. The 1.2% rate matters everywhere the directive does not reach: portfolio stakes below 10%, holdings younger than a year, and EEA recipients outside the EU (Norway, Iceland, Liechtenstein). An EU holding or investment company collecting dividends from minority positions in Italian businesses keeps 98.8% at the border instead of 74%.[1][3]
The catch
The recipient must genuinely be subject to corporate tax in its home state - exempt vehicles do not qualify - and must be the beneficial owner of the dividend, not a conduit inserted for the rate. Individuals get nothing here: a foreign individual pays 26% (or the treaty rate), and an Italian resident pays a 26% final tax. The 1.2% is a corporate-shareholder feature, not a general exit route from Italian dividend taxation.[1]
Często zadawane pytania
Does the 1.2% rate require a minimum shareholding?
No - that is its point. The Parent–Subsidiary 0% needs ≥10% held for a year; the 1.2% applies to any EU/EEA company subject to corporate tax, including sub-10% portfolio stakes.
Do individuals ever get the 1.2%?
No. It mirrors the 95% exemption available to corporate shareholders. Individuals - resident or not - face the 26% flat rate, reduced only by treaties.
Is there an equivalent for interest and royalties?
Not at 1.2%. Interest to non-residents is withheld at 26% and most royalties at an effective ≈22.5%, with 0% between associated EU companies under the Interest & Royalties Directive.
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Źródła
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