The 2026 Budget Bill introduces a significant change in the taxation of dividends received by companies. Starting from January 1, 2026, the tax regime that has been consolidated for over twenty years will undergo substantial modifications that will impact how companies tax profits received from shareholdings.
What changes from January 1, 2026
Currently, dividends received by companies contribute to taxable income for only 5% of their amount (95% exclusion). Under the new legislation, this tax benefit will be recognized only for companies holding at least 10% direct ownership in the distributing company at the time of the distribution resolution.
Who is affected by the new rules
The new provisions apply to corporations and partnerships. For shareholdings that do not reach the 10% threshold, dividends will contribute in full (100%) to taxable income. The taxation methods for individuals remain unchanged.
Indirect holdings and foreign dividends
The 10% requirement can also be met through indirect holdings held through controlled companies, applying the demultiplication effect along the control chain. The criteria also apply to foreign-source dividends.
Effective date: the resolution date matters
The new rules will apply to distribution resolutions adopted from January 1, 2026, regardless of the actual payment date. Therefore, it is the date of the shareholders’ resolution that determines the applicable tax regime, not the moment of actual dividend payment.
What to do before December 31, 2025
For those holding shareholdings below 10% and expecting to receive dividends, it may be advisable to consider extraordinary operations or early resolutions by year-end, to still benefit from the current more favorable regime.
Studio RCG remains available to analyze each company’s specific position and evaluate any actions to be taken by December 31, 2025.