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 natural person, by the transferee and its family members pursuant to Article 5, paragraph 5 of the TUIR. On the other hand, the further condition required by the rule for the application of the controlled realisation regime, i.e., the exceeding of the qualification thresholds in respect of the individual participations transferred, remains unaffected.