Legislative Decree 139/2024 has introduced significant changes regarding the exemption from inheritance and gift tax for the transfer of businesses and shareholdings. These new provisions aim to facilitate generational business transfers by offering greater clarity and expanding tax benefits.
The previous legislation already provided for a full exemption from inheritance and gift tax for heirs who maintained control or continued the business activity for at least five years. With Legislative Decree 139/2024, this regime becomes even clearer and more inclusive, extending to previously excluded cases (such as the consolidation of an already existing control) and also to shareholdings in foreign companies.