On 21 May 2009, the Italian Tax Administration (ITA) issued Circular Letter No. 26/E (the "Circular"), which clarifies the tax treatment of dividends paid to residents of a EU Member State or of a country that is part of the European Economic Area (EEA).
According to Art. 27–ter of Italian Presidential Decree No. 600/1973, as modified by the2008 Budget Law , dividends distributed by an Italian company to entities that are resident of a EU or EEA country qualify…