The Italian Revenue Agency (Agenzia delle Entrate), by means of its reply No. 8 of 21 January 2025, has ruled on the issue of dividend washing:

According to the Agenzia delle Entrate, the provision on dividend washing is not applicable whenever the shareholdings do not meet the objective PEX requirements, i.e. they are related to entities resident in countries with privileged taxation or that do not carry out commercial activities.