NEWS
Capital gains subject to PEX – Participation Exemption – partial exemption and related tax credit
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 [...]
Transfer of shareholdings: PEX regime for non-EU companies
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 [...]
Deduction of ancillary costs for shareholdings generating a PEX (Participation Exemption)
The Italian Revenue Agency (Agenzia delle Entrate), in its response to a ruling request dated 7 April 2025, No. 90, clarified that ancillary costs directly related to the disposal of shareholdings generating a PEX (Participation [...]
Changes regarding the exemption from inheritance and gift tax for the transfer of businesses and shareholdings
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 [...]
Contributions of Shareholdings in EU Entities – Tax Neutrality
Legislative Decree No. 192/2024, reforming IRPEF and IRES, has extended the subjective scope of application of Article 177(2) of the TUIR, which governs the so-called "controlled realisation" regime for share swaps through contributions, to include [...]
Waiver of Dividends – Legal Receipt – Application of the 26% Withholding Tax under Article 27 of DPR 600/73
In its response to ruling request No. 59/2025, the Italian Revenue Agency states that a waiver by individual shareholders of dividends already declared constitutes their legal receipt, thereby necessitating the application of the withholding tax [...]