The draft 2026 Budget Law radically redesigns the domestic dividend regime, introducing a minimum threshold of 10% shareholding for income tax exemption.

This reform marks the transition to a system that provides for tax exemption only if the investment is “significant,” with significant impacts on holding companies, corporate ventures, and multi-company structures.

In his in-depth analysis on Bluerating, advisory & asset management, our Partner Domenico Ponticelli analyzes the three technical pillars of the measure—binary logic, look-through mechanism, and shift to a percentage basis—and assesses its systemic implications, compares it with European regimes, and suggests possible corrective measures to reduce its distorting effects.