Contribution of non-controlling interests in ‘controlled realisation’ – Family-owned transferee company – New provisions of Legislative Decree No. 192/2024

Contributions of qualified minority interests made after 31 December 2024 are subject to the provisions of Article 177, paragraph 2-bis, of the Consolidated Income Tax Act, as amended by Article 17 of Legislative Decree 192/2024. Under the new rules, the transferee company must be owned solely by the transferor or, if the transferor is a [...]

2025-01-06T19:42:44+01:00January 6th, 2025|Unkategorisiert|

The possibility of dematerialising special categories of shares in small and medium-sized limited liability companies and the resulting obligation to keep the shareholders’ register

Law no. 21/2024 (the so-called ‘Capital Law’) has only introduced the possibility for small and medium-sized limited liability companies to issue special categories of dematerialised shares that circulate through mere book-entry transactions and that are issued alongside ordinary shares in crowdfunding transactions.

2024-12-17T13:24:59+01:00December 17th, 2024|Unkategorisiert|

Dividends from Croatia – refund of the higher Italian tax due to the impossibility of offsetting the tax from abroad

Dividends received from Croatia by resident individuals are normally subject to Article 27(4) of Presidential Decree 600/73, which provides for a withholding tax of 26% on the total dividend received, without distinguishing between qualifying and non-qualifying holdings. This withholding tax is withheld after the foreign dividend has already been taxed at source in Croatia (in [...]

2024-12-17T13:24:06+01:00December 17th, 2024|Unkategorisiert|

VAT on secondment of staff: Effects from 2025

From 1 January 2025, the hiring and secondment of employees will be subject to VAT. There is generally no change for industrial and service companies that enjoy the full right to deduct input tax, while for companies without input tax deduction (banks, insurance companies, doctors, clinics, etc.) the new regulation represents a significant change (= [...]

2024-12-17T13:23:20+01:00December 17th, 2024|Unkategorisiert|
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