It will begin with an analysis of the tax consequences arising from the contribution of shareholdings in Swiss and Italian holding companies by Italian tax residents, highlighting the main critical aspects such transactions may entail. This will be followed by an in-depth discussion of the taxation of foreign dividends received by individuals resident in Italy and of the right to a foreign tax credit for taxes paid abroad — a topic currently marked by a sharp interpretative divergence between the Italian Revenue Agency, which denies the right to the credit, and the Supreme Court (Corte di Cassazione), which has ruled in favor of taxpayers.
Under the Convention against Double Taxation between Switzerland and Italy, dividends may be taxed in Switzerland at a maximum withholding rate of 15% and in Italy at a substitute tax rate of 26% on the so-called “net frontier” amount. However, the absence of an automatic recognition of the foreign tax credit under domestic law results in double taxation and significant operational uncertainty, which will be examined in detail during the webinar.
The next session will address the tax treatment of dividends distributed by an Italian subsidiary to a Swiss parent company, with particular focus on the role of Article 9 of the CH–EU Agreement on the automatic exchange of information. Although many tax treaties concluded by Switzerland already provide for a full exemption from withholding tax on cross-border dividends, this Agreement continues to play a crucial role in relations with Italy.
Finally, the webinar will analyze a recent decision of the Court of Justice of the European Union, which declared incompatible with EU law the Italian rules including, in the IRAP taxable base, dividends received by an Italian parent company from its foreign subsidiaries that have already been subject to corporate income tax (IRES). The Court reaffirmed that, under the exemption system, a Member State must exclude such income from any further taxation to avoid economic double taxation and to uphold the principle of tax neutrality.

Programme and Speakers
The tax treatment of share contributions to Italian and Swiss holding companies
Pierpaolo Angelucci
Certified Public Accountant, Scarioni Angelucci Studio Tributario Associato, Milan

Foreign tax credit or “net frontier”? Taxation of Swiss-source dividends in Italy
Alessia di Sbrojavacca
Chartered Accountant, Auditor, Researcher in Tax Law at the University of Trieste, freelance journalist, PhD in Legal Sciences

Taxation of dividends distributed by Italian subsidiaries to Swiss parent companies
Carlo Castellano
Master of Advanced Studies SUPSI in Tax Law, Certified Finance and Accounting Specialist, Licensed Auditor (ASR), Corporate & Tax Advisor at Fiduciaria Fontana SA, Chiasso

Taxation of cross-border dividends received by Italian financial intermediaries
Andrea Manzitti
Lawyer, Partner at BonelliErede, Adjunct Professor of Tax Law, Bocconi University, Milan

Fee
CHF 350.–
CHF 50.– discount for members of partner institutions

Registration
https://bit.ly/webinar-12-01-2026