The Italian Revenue Agency has issued Circular No. 17/E of 29 July 2024, which clarifies the participation exemption for capital gains from the sale of shareholdings by qualifying non-resident companies. As part of the Budget Law for 2024, the domestic participation exemption (95% exemption) for capital gains on the disposal of qualifying shareholdings was extended so that it is also available for qualifying non-resident companies without a permanent establishment in Italy that meet the foll…