Guiding principle – Mission – Contact
We are auditors and tax consultants based in Meran, Italy.
Our aim is to act quickly and in a client-oriented manner to create sustainable added value. You as our client are our main focus and we strive to provide you with customized, comprehensive and personal service. You can expect the highest level of reliability, expertise and commitment from us for an appropriate fee.
Domestic consulting
We advise domestic and local clients on tax, commercial, contractual and economic matters. With our many years of experience, a compact, goal-oriented team and an extensive network, we would like to provide you with comprehensive advice on your business and economic decisions. We are also happy to advise you on specialized topics.
German-speaking countries
Our location in South Tyrol (with German as an official language) and our knowledge of the different cultural and linguistic areas enable us to advise you on your tax and economic decisions in Italy. Our network and access to Italian markets, banks and institutions is an advantage in this regard.
News
Uninterrupted ownership (the “holding period”) – Shareholding acquired as a result of a contribution under the “controlled realisation” tax regime or by way of a demerger (“scissione mediante scorporo”) – Effects
With regard to a demerger by way of a “scissione mediante scorporo” pursuant to Article 2506.1 of the Italian Civil Code, involving the transfer to a pre-existing beneficiary company of assets other than a business [...]
Costituzione di nuova società e sottoscrizione del capitale sociale – Holding period
In merito, si pone il dubbio interpretativo sulla sussistenza dei requisiti per beneficiare della pex, in considerazione dell'esistenza di partecipazioni acquisite nella fase di costituzione della conferitaria e di partecipazioni acquisite/ricevute successivamente in cambio del [...]
Incorporation of a New Company and Subscription of Share Capital – Subsequent Capital Increase by Means of a Business Contribution under Tax Neutrality – Transfer of the Participation Received – Holding Period
The analysis concerns the case of a business contribution followed by the disposal of the participation received in exchange. In this regard, an interpretative question arises as to whether the conditions for benefiting from the [...]
Corporate link – Significant influence – Family or affinity relationships – Corporate group
In its judgment of 13 April 2026, No. 9260, the Supreme Court held that an external corporate link requires proof of the actual exercise of significant influence by one company over the strategic shareholders’ decisions [...]
Consultancy costs recharged by the parent company – Deductibility – Conditions (Supreme Court, 21 April 2026, No. 10456)
The ruling of 21 April 2026, No. 10456 addresses the requirement of business relevance under Article 109 of the Italian Income Tax Code (TUIR) and the deductibility of consultancy services recharged by a parent company [...]
Commerciality requirement – Companies constructing electricity generation plants – Absence (Italian Revenue Agency ruling of 1 April 2026, No. 97)
According to the ruling of the Italian Revenue Agency dated 1 April 2026, No. 97, the disposal of shareholdings in companies engaged in the construction of electricity generation plants does not meet the commerciality requirement [...]