Italian Tax Court of Appeals of Abruzzo Holds U.S. Company Qualifies for 1.2% Tax Rate on Dividends

The Italian Tax Court of Appeals of Abruzzo issued Decision 93/2026 on 17 February 2026, concerning the eligibility of a U.S. company for the 1.2% tax rate that applies for dividends paid by Italian companies if certain conditions are met. The case involved a U.S. company that held 35% of an Italian company. In 2018, the Italian company distributed dividends to the U.S., applying a 5% withholding tax rate in accordance with the provisions of the Italy-U.S. tax treaty (requires at least 25% h…