Italy's 2021 Finance Law introduced a 0% withholding tax rate on Italian-source dividends where the EU/EEA recipient is either a fund regulated under the UCITS IV Directive, or a non-UCITS fund managed by an entity subject to supervision under the AIFM Directive. The withholding tax exemption has also been extended to capital gains realized by the same qualifying funds on qualifying participations.
In a recently released private ruling no. 148/2024, the Italian tax agency was asked to confir…