We are writing to inform you of the recent regulatory changes introduced by Decree Law No. 38 of 27 March 2026 (the so-called “tax decree”), which came into force on 28 March 2026, concerning the treatment of dividends and capital gains.
Article 11 of the aforementioned tax decree reinstates the tax regimes for dividend exemptions and the so-called Participation Exemption that were in force prior to the amendments introduced by the 2026 Budget Law (Law No. 199 of 30 December 2025).
The provisions of the tax decree apply from 1 January 2026, meaning that the legislation introduced by the 2026 Budget Law is, in effect, NEVER applicable. The ordinary legislation in force prior to the 2026 Budget Law therefore continues to apply without interruption.
Without commenting on the merits of the proposed changes set out in the 2026 Budget Law, the effect is essentially a complete reversal.
