Law no. 205/2017 modified the dividend taxation regime with the provision, for non-business IRPEF entities, of a 26% withholding tax, regardless of whether they hold qualified or non-qualified shareholdings.
However, for non-entrepreneurs Irpef subjects who have qualified shareholdings, there is a transitional regulation applicable to profits produced up to the financial year in progress on 31 December 2017 and whose distribution is resolved on a date between 1 January 2018 and 31 December 2022. These profits are subject to the previous rules, which provide that dividends are not subject to any withholding tax but are subject to IRPEF with equal taxable income:
– 40% if the profit was formed up to the financial year in progress on December 31 2007;
– 49.72% if the profit was formed after the current financial year on 31 December 2007 and until the current financial year on 31 December 2016;
– 58,14% if the profit was made after the current financial year on 31 December 2016.