At the outset, the webinar will analyse the changes introduced by Law No. 199 of 30 December 2025 (the so-called 2026 Budget Law) with regard to the partial tax exemption regime applicable to dividends under Articles 59 and 89 of the Italian Income Tax Code (TUIR) and to capital gains under Articles 58 and 87 of the TUIR (the so-called participation exemption). In particular, the 2026 Budget Law provides that the partial exclusion from taxable income may be applied on condition that the shareholding held amounts to at least 5% of the share capital or, alternatively, has a tax value of not less than EUR 500,000. Below this threshold, dividends and capital gains will be fully included in taxable income.
The webinar will then examine the specific exclusion from the obligation to levy the additional 10% IRPEF surtax on bonuses and stock options paid to executives and directors in the financial sector pursuant to Article 33 of Decree-Law No. 78/2010. In particular, the surtax does not apply if the entity (company or other body) paying such remuneration pays to Third Sector entities an amount at least equal to twice the surtax that would otherwise be due.
The latest clarifications issued by the Italian Revenue Agency will also be illustrated with regard to incentive schemes granted to employees in cross-border situations, with particular reference to bonuses and stock options accrued during a period of employment in one State and subsequently received while resident in another State.
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 1, paragraphs 25–26, of the 2026 Budget Law. The measure, applicable to individuals who transfer their civil residence to Italy pursuant to Article 43 of the Italian Civil Code as from 1 January 2026, increases the amount of the substitute tax due from EUR 200,000 to EUR 300,000. In this context, the compatibility of the new residents regime with the inbound workers regime will also be examined in light of the most recent rulings issued by the Italian Revenue Agency.
Finally, a session will be dedicated to the amendments introduced by the 2026 Budget Law to the rules on super-depreciation (iper-ammortamenti) for direct tax purposes, with regard to investments in assets produced in one of the Member States of the European Union or in States party to the Agreement. Particular attention will be paid to the exclusion of Switzerland from this measure and to the possible limitations for Swiss manufacturers, despite the more than 120 bilateral agreements between Switzerland and EU countries, as well as Switzerland’s membership of the Schengen area.

Programme and speakers
Amendments to the rules on dividends and capital gains realised on securities held by companies
Pierpaolo Angelucci
Chartered accountant, Scarioni Angelucci, Studio tributario associato, Milan

The 10% IRPEF surtax on bonuses and stock options for executives and directors in the financial sector – latest clarifications from the Italian Revenue Agency on incentive schemes granted to employees in cross-border cases (bonuses and stock options accrued during a period of employment in one State and received while resident in another State)
Andrea Bracchi
Chartered accountant, Legance – Avvocati Associati, Milan

The increase in the substitute tax for new residents opting for the flat tax regime – compatibility with the inbound workers regime – recent guidance issued by the Italian Revenue Agency
Roberto Bonomi
Chartered accountant and partner in the Private Client and Tax team at Withers, Milan

The introduction of super-depreciation for income tax purposes for investments in assets produced in one of the Member States of the European Union or in States party to the Agreement: exclusion of Switzerland
Gianluigi Bizioli
Full Professor of Tax Law and International and EU Tax Law at the University of Bergamo, Of Counsel, PwC Tax and Legal Services, Milan

Fee
CHF 350
Discount of CHF 50 for members of partner organisations

Registration
https://bit.ly/webinar-10-03-2026

Registration deadline
Friday, 6 March 2026