Eni’s corporate map stretches well beyond Italy. Its 2025 accounts list several holding and investment companies in the Netherlands, including Eni International BV and Eni Netherlands Holding BV. Some assets located elsewhere are also structured through Dutch entities.
That matters because Eni is not an ordinary private multinational: the Italian state, directly and through Cassa Depositi e Prestiti, controls about 33% of the company. This makes the fiscal architecture particularly interesting. Why are foreign revenues, dividends or assets routed through Dutch holding companies rather than directly through Italy? Are there advantages involving withholding taxes, investment treaties, financing or profit distribution?
Such structures can have perfectly legitimate commercial purposes. But given the Italian state’s position in Eni, it is reasonable to examine whether they also reduce, defer or relocate taxes that might otherwise be collected in Italy.