We wish to update you on the final structure of the provisions concerning the taxation of dividends and capital gains realized by entrepreneurs, or resident companies and entities, following the entry into force of Law No. 199 of 30 December 2025 (“2026 Budget Law”).
This Circular fully replaces our previous Communication No. 28/2025 dated 14 November 2025, which commented on the original draft of the Budget Bill.
The final approved text of the law contains significant amendments compared to the initial version, introducing different requirements for access to the dividend exclusion regime and extending the measure to the capital gains exemption regime applicable to shareholdings.
