An examination of recent amendments to the participation exemption (PEX) regime: In this article, LED Taxand explores recent amendments to Italy’s PEX regime in case of foreign subsidiaries and considers why taxpayers may need further clarification.
Indeed, following the amendments, including the provision of new criteria for qualifying a foreign state or territory as blacklisted, several doubts have arisen among the scholars, in particular with respect to the taxation of dividends and capital gains derived from participations held by taxpayers before 2019.
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