An opinion by Advocate General (AG) Kokott of the Court of Justice of the European Union (CJEU) was recently delivered concerning whether relief from the Italian regional tax on productive activities (IRAP) should be provided under the EU Parent-Subsidiary Directive. The case involves Banca Mediolanum SpA, an Italian bank, which received dividends from its subsidiaries in Ireland, Luxembourg, and Spain in 2014. Considering that the conditions for exemption under the Parent-Subsidiary Directi…