CJEU Holds Italian IRAP on Dividends Violates Parent-Subsidiary Directive

The Court of Justice of the European Union (CJEU) issued a judgment on 1 August 2025 concerning whether relief from the Italian regional tax on productive activities (IRAP) should be provided under the EU Parent-Subsidiary Directive (Directive 2011/96). 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 Directive were met, a…