Il regime dei dividendi in «entrata» e l’istituto del credito di imposta «indiretto», anche alla luce della giurisprudenza europea

The objective of this paper is to analyze the tax regime of «inbound» dividends into the State with the aim of identifying the main elements characterizing the current legislation. This examination is of fundamental importance not only to outline the boundaries of the application’s scope of current legislation with specific regard to foreign-source dividends from Countries with privileged taxation regime, but also for the purposes of the subsequent analysis of the «indirect» tax credit institution. In addition to taking into account the practice documents of the Italian Tax Authority, part of the paper is reserved for the discussion of recent European jurisprudence on dividends deriving from third States and its impact on the Italian legal system.