The webinar will address certain Italian tax law topics of particular relevance for both national and international operators, in light of the most recent legislative developments and administrative practice. In particular, it will examine the changes introduced by the 2026 Budget Bill concerning the regulation of dividends and the optional substitute tax regime for new residents, the updates regarding the inbound workers regime, as well as the amendments introduced in the area of inheritance and gift tax, with specific reference to the exemption applicable to certain types of companies. The session will open with an analysis of the new provisions in the 2026 Budget Bill concerning dividends, which modifies the partial tax exemption regime provided under Articles 59 and 89 of the TUIR. Specifically, it establishes that the exclusion from taxable income may only apply where a direct participation, including one held through controlled companies, is not less than 10%. Below this threshold, dividends will be fully included in taxable income.
This will be followed by an in-depth analysis of the amendments to the optional regime for new residents under Article 24-bis of the TUIR, in light of Article 11 of the same Budget Bill. The measure, applicable to individuals transferring their tax residence to Italy from 1 January 2026, increases the annual substitute tax on foreign-source income from EUR 200,000 to EUR 300,000, while also raising from EUR 25,000 to EUR 50,000 the substitute tax payable for each family member to whom the regime is extended.
Next, the webinar will examine the latest updates on the inbound workers regime in light of recent clarifications issued by the Italian Revenue Agency, highlighting remaining opportunities and risks in the context of international mobility. Finally, a session will be dedicated to the amendments introduced by Legislative Decree No. 139/2024 concerning inheritance and gift tax, with particular reference to the exemption provided for in Article 3(4-ter) of Legislative Decree No. 346/1990, which establishes that, under certain conditions, transfers to direct descendants or the spouse of businesses, company shares, and stock holdings are exempt from inheritance and gift tax. The provision will be analysed considering the numerous interpretative challenges it has raised since its introduction, stemming from both its wording and the interpretative approaches adopted by the Revenue Agency and the Supreme Court.

Programme and speakers
Recent developments on dividend taxation in the 2026 Budget Bill
Pierpaolo Angelucci
Certified Public Accountant, Scarioni Angelucci, Associated Tax Firm, Milan

Revision of the flat tax for new residents under Article 24-bis TUIR
Andrea Ballancin
Lawyer and Certified Public Accountant, Associate Professor of Tax Law, University of Eastern Piedmont, Partner at MB e Associati – Tax Law Firm, Milan

The inbound workers regime between recent practice and planning strategies
Roberto Franzè
Adjunct Professor of Tax Law, University of Valle d’Aosta

Inheritance and gift tax: new rules on business transfers and company shareholdings
Paolo Piantavigna
Associate Professor of Tax Law, University of Pavia, Attorney admitted before the Court of Cassation, Milan

Fee
CHF 350.–
CHF 300.– for members of partner institutions

Registration
https://bit.ly/webinar-17-12-2025

Registration deadline
Monday, 15 December 2025