Why there are four possible rates, and not one
When an Italian company pays a dividend, the tax is collected before the money leaves: the company acts as withholding agent, applies a rate to the gross dividend and pays the net amount to the shareholder. For a shareholder who is not resident in Italy the withholding is a final tax (a titolo d'imposta), which in the ordinary case means the shareholder files no Italian return for that income. Which rate applies depends on who the shareholder is and on the paperwork that reaches the Italian company before the payment.
| Route | Rate | Who can use it | Source |
|---|---|---|---|
| Ordinary rate | 26% | Any non-resident shareholder, individual or company | Art. 27(3), DPR 600/1973; rate set by art. 3(1), D.L. 66/2014 |
| EU/EEA company | 1.2% | Company resident in an EU/EEA State on the list, subject to corporate tax, no minimum holding | Art. 27(3-ter), DPR 600/1973, as replaced by art. 11, D.L. 38/2026 |
| EU parent company | 0% | Direct holding of at least 10% for 12 uninterrupted months, EU legal form, subject to tax without an option or exemption regime | Art. 27-bis, DPR 600/1973; Directive 2011/96/EU |
| Treaty rate | 5% – 15% | Resident of a State with a treaty, beneficial owner, documents before payment | Art. 10 of the individual treaty |
| Pension funds and PEPP | 20% | EU/EEA pension funds and pan-European individual pension products | Art. 27(3), second sentence, DPR 600/1973, as amended by D.Lgs. 148/2026 |
The 26% ordinary rate, and the 27% you will read elsewhere
The first sentence of article 27(3) of Presidential Decree 600/1973 still reads “27 per cent”. That figure is not the rate in force: article 3(1) of Decree-Law 24 April 2014, no. 66, set the withholding and substitute taxes on the income of article 44 of the Income Tax Code — dividends among them — at 26%, with effect from 1 July 2014 under article 4(1) of the same decree. The refund fraction written into the same paragraph, 11/26, is itself built on 26%: 26% minus 11% leaves 15%, the Italian tax that survives the refund. This calculator uses 26%, and this is the one point where reading only article 27(3) leads to the wrong answer.
The 1.2% rate for EU and EEA companies, with no holding threshold
Article 27(3-ter) applies a 1.2% rate to dividends paid to companies and entities subject to a corporate income tax in an EU or EEA State included in the exchange-of-information list, resident there, on participations not attributable to an Italian permanent establishment. In the text in force there is no minimum holding and no minimum value. The 2026 Budget Law had introduced thresholds — a direct holding of at least 5% of the capital or a fiscal value of at least €500,000 — for distributions approved from 1 January 2026, but article 11 of Decree-Law 27 March 2026, no. 38, replaced article 27(3-ter) with the version without thresholds and repealed those provisions with effect from 1 January 2026. Sources published between December 2025 and January 2026 still carry the thresholds: they no longer exist.
The 0% parent-subsidiary route
Article 27-bis implements the EU parent-subsidiary directive. A parent company with a direct holding of at least 10% of the capital — the article reads 20%, reduced to 10% for profits distributed from 1 January 2009 — held uninterruptedly for at least one year, in a legal form listed in the annex to Directive 2011/96/EU, resident in an EU Member State and subject there to one of the taxes of the Directive without an option or exemption regime, can have the withholding not applied at all. Two documents are needed: a certificate of the foreign tax authority on residence, legal form and tax status, and a declaration by the company on the year of holding. They must be with the Italian company by the payment date; if they are not, the domestic rate is applied and the exemption is claimed as a refund. Note the difference from the 1.2% rate: that one covers the EEA as well, this one requires an EU Member State.
Treaty rates on dividends
Double tax treaties reduce the Italian tax on dividends, usually to 15% for an individual and to 5% or 10% for a company with a substantial holding. The table below lists only the countries whose dividend article has been verified for this tool. For any other country the calculator asks you to type the rate: it accepts the figure without checking it against the treaty, and says so.
- United States: 15%; 5% for a company holding at least 25% of the voting stock for 12 months ending on the declaration date — art. 10(2).
- United Kingdom: 15%; 5% for a company controlling, directly or indirectly, at least 10% of the voting power — art. 10(2), subject to the anti-abuse rule of art. 10(9).
- Germany: 15%; 10% for a company owning directly at least 25% of the capital — art. 10(2) and (3).
- France: 15%; 5% for a company holding, directly or indirectly, at least 10% of the capital for the 12 months before the declaration — art. 10(2).
- Switzerland: 15% single cap, with no reduced rate for a qualifying holding — art. 10(2).
- Spain: 15% single cap, with no reduced rate for a qualifying holding — art. 10(2).
- Netherlands: 15%; 10% for at least 10% of the voting shares held for 12 months; 5% above 50% — art. 10(2).
Two warnings that apply to every treaty route. First, the reduced rate belongs to the beneficial owner of the dividend: a company interposed without substance is exposed both to the treaty clause and to the general anti-abuse rule of article 10-bis of Law 212/2000. Second, the Swiss article 10 as verified fixes a single 15% cap; the amending protocol signed in Milan on 23 February 2015 (ratified by Law 69/2016, in force since 13 July 2016) should be checked on that article before relying on the rate.
The documents that decide the rate
A reduced rate or a treaty cap applies from the payment date on one condition: the Italian company must already hold the documents. For treaty relief these are a certificate of residence issued by the foreign tax authority and the treaty form. The Revenue Agency's measure of 10 July 2013, no. 84404, introduced universal forms for the refund, the exemption or the application of the reduced rate, with Form A for dividends (Forms B and C cover interest and royalties); agreed forms, negotiated with the individual State, exist for Germany, Portugal, the United Kingdom, the United States, Sweden and Switzerland. A parent company claiming the article 27-bis exemption uses the certificate and declaration of that article instead.
If the documents arrive after the payment, the Italian company has no choice: it applies the 26% domestic rate, and the shareholder asks the Agenzia delle Entrate for the excess. That is a refund route, not a penalty — but it is the shareholder, not the company, who has to open it, with the foreign tax certificate attached.
The 11/26 refund, and why it is a ceiling
A non-resident shareholder who has paid the 26% at source can claim back the Italian tax on the same profits up to 11/26 of the withholding applied, where the same profits were taxed abroad definitively and the foreign tax is proved by a certificate of the competent foreign tax office. With the 26% rate, 11/26 of the withholding is 11% of the gross dividend: the refund leaves 15% of Italian tax in place, and it can never exceed the foreign tax actually proved. Shareholders excluded from this refund are, among others, companies and entities covered by article 27(3-ter) — the ones that benefit from the 1.2% rate — savings shareholders, pension funds and PEPP sub-accounts.
The claim is filed with the Agenzia delle Entrate and the amount is never guaranteed: it depends on the certificate of the foreign tax authority and on the Agency's assessment. This page deliberately says nothing about the time limits for filing it, for the company's payment of the withholding or for the refund where the holding period is completed after the payment, because those points are not verified on primary sources. Ask your accountant for the deadlines that apply to your case.
What the calculator does not do
- It does not decide your residence or your beneficial ownership: you tell it, and it applies the consequences.
- It does not check the treaty rate you type in for a country outside its list.
- It does not cover participations attributable to an Italian permanent establishment.
- It does not compute the Italian company's own obligations as withholding agent, nor the shareholder's foreign tax.
- It gives an estimate on the facts entered. It is not tax advice, and it does not replace a check of your own documents.
Where the rates come from
- Art. 27, comma 3, D.P.R. 600/1973 (aliquota vigente: art. 3 D.L. 66/2014)
- Art. 27, comma 3-ter, D.P.R. 600/1973 (come sostituito dall'art. 11 D.L. 38/2026)
- Art. 27-bis, D.P.R. 600/1973
- Dipartimento delle Finanze — Convenzioni per evitare le doppie imposizioni (testi pubblicati)
- Agenzia delle entrate — Convenzioni contro le doppie imposizioni: modelli e istruzioni (provv. 84404/2013: modulo A dividendi)
- Direttiva 2011/96/UE (madre-figlia), allegato delle forme societarie
Every rate and threshold on this page was read on the text in force on 23 settembre 2026. The verification, claim by claim, is in the fact-check file of this page.
From 1 January 2027 these rules move to Legislative Decree 33/2025, the consolidated law on tax payments and collection, which restates them without changing the rates shown here.
Related reading
- Italian taxes for a foreign-owned company — the corporate taxes behind the dividend, and the cross-border issues to discuss with an accountant.
- English-speaking accountant in Italy — what an Italian commercialista does, how to verify one, and how to switch.
- All the tools with an English interface.