On 8 July 2011, the Italian Revenue Agency issued circular letter no. 32/E (the Circular), clarifying the requirements that EU-resident companies must fulfill to qualify for the reimbursement of Italian tax withheld on dividends distributed up until 2008.

The Circular may have an impact on foreign taxpayers that have already filed reimbursement claims with the Italian tax authorities or are still within the 48-month grace period to do so. In fact, the Italian Revenue Agency has officially recognised for the first time that reimbursements are due for dividend-withholding taxes levied until 2008 and has provided guidance to local offices to abandon relevant litigations that are before tax courts.