Minimum shareholding of 5% or EUR 500,000 – Changes introduced by Law No. 199/2025 (2026 Budget Law)

For all foreign-source dividends resolved as from 1 January 2026, the 95% exemption from inclusion in business taxable income is subject to the same conditions applicable to Italian-source dividends, pursuant to the new Article 89, paragraph 2.1, letter (a) of the Italian Income Tax Code (TUIR).

Such conditions require a shareholding in the issuer’s capital of at least 5% or, alternatively, a tax basis of the participation of at least EUR 500,000.