Italy: Revocation of the new requirements for the application of 1.2 pct tax rate to EU/EEA corporation
LuxCSD1 informs clients that the Government approved Decree-Law No. 38 of 27 March 2026, amending some paragraphs of the 2026 Budget Law (No. 199/2025), results in the revocation of the new requirements to obtain the benefits of the 1.2 pct withholding tax rate. This is further to Announcement L26006.
Effective
immediately
the old procedure to benefit from the 1.2 pct at relief at source remains valid for all upcoming payments and applies retroactively from 1 January 2026, if applicable.
Impact on clients
For all dividend payments paid in 2026, including those approved in 2026, the 1.2 pct reduced rate is still applicable via the existing relief at source procedure.
To obtain relief at source on the dividend payments, clients must provide LuxCSD with the following documentation by the prescribed deadlines:
- One-Time Certificate for Italian Equities;
- One-Time Master Instruction/Dividends at Source (O.T.M.I.);
- Certificate of Residence for 2026;
- Italian Equities: List of Beneficial Owners.
Clients should refer to Market Taxation Guide - Italy for further information about the withholding tax procedures for Italian equities.
Further information
Clients may contact the Tax Help Desk, LuxCSD Client Services or their Relationship Officer.
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1. LuxCSD refers to LuxCSD S.A., registered office at 42, Avenue J.F. Kennedy, L-1855 Luxembourg, registered with the Luxembourg Trade and Companies Register under number B-154.449.