IRAP on dividends: according to CJEU is contrary to EU law and must be refunded

With the judgement in joined cases C-92/24 to C-94/24 of August 1st, 2025, the Court of Justice of the European Union (“CJEU”) ruled that Italy's regional tax on production activities (“IRAP tax”) on dividends received by Italian financial intermediaries as parent companies from subsidiaries in other Member States violates the Parent Subsidiary Directive (“PSD”) and must be therefore reimbursed.