Italy's Ministry of Economy and Finance has issued the Decree of 26 June 2023. The Decree provides for the implementation of the one-off substitute tax on undistributed profits and retained earnings reserves of subsidiaries benefitting from a privileged tax regime (i.e., profits that would not qualify for participation exemption), which was introduced by Law No. 197 of 29 December 2022 on the State Budget for 2023. As previously reported, the one-off substitute tax may be claimed in the tax …