Waiver of Dividends – Legal Receipt – Application of the 26% Withholding Tax under Article 27 of DPR 600/73

In its response to ruling request No. 59/2025, the Italian Revenue Agency states that a waiver by individual shareholders of dividends already declared constitutes their legal receipt, thereby necessitating the application of the withholding tax under Article 27 of DPR 600/73.