The waiver of dividends by individual shareholders who are not entrepreneurs does not generate taxable extraordinary income for the investee company, as the shareholders’ receivable corresponds to the nominal value of the dividends. However, since the dividends have already been resolved, they are deemed to have been received by the shareholders and are therefore subject [...]
In the case of companies that exercise the branch exemption (BEX) option and transfer their tax residence abroad, the capital gain relating to the foreign permanent establishment is not relevant for Exit Tax purposes (Italian Revenue Agency Ruling No. 185 of 8 July 2025).
June 30 marks the deadline for filing the web tax declaration for the 2024 tax period. This obligation concerns the self-assessment of the tax due on digital services, through which the revenues subject to taxation are declared.
The law on employee participation in company management, capital, and profits – definitively approved by the Senate on 14 May 2025 – is pending publication in the Official Gazette. In implementation of Article 46 of the Italian Constitution, the law governs four forms of employee participation: managerial; economic and financial; organisational; consultative. Under economic and [...]
The Italian Revenue Agency, in its response no. 129 dated May 13, 2025, clarified that proceeds from the transfer of surface rights alone are classified as miscellaneous income and are no longer subject to capital gains taxation.
Taxes paid abroad entitle the taxpayer to a foreign tax credit under Article 165 of the Italian Income Tax Code (TUIR), provided that: They relate to income earned in a foreign country; Such income is included in the total income of the Italian resident taxpayer; The foreign taxes have been paid definitively (i.e., there is [...]
A company director is jointly liable for the payment of VAT debts if no insolvency petition has been filed – unless they can prove that they managed the company with due diligence (CJEU, 30 April 2025, C-278/24).
The response to ruling request No. 101 issued by the Italian Revenue Agency on 15 April 2025 confirmed the application of Article 165(10) of the TUIR to the tax paid in France in connection with the capital gain realised on a shareholding in a French company held by an Italian-resident company. This gain is taxable [...]
In its Reply No. 101 of 15 April 2025, the Italian Revenue Agency provided clarifications regarding the tax credit on tax paid in France in relation to capital gains subject to the PEX regime. The inclusion of foreign-sourced income in the calculation of total taxable income in Italy is a necessary condition for subsequently deducting [...]
On April 9, 2025, the Italian Association of Chartered Accountants (AIDC) published Interpretation No. 229 regarding the application of the PEX regime to capital gains from the sale of shareholdings in resident companies by entities not resident in the EU or EEA. The AIDC Interpretation No. 229 of April 9, 2025, aims to outline the [...]