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 Exemption) capital gain are deductible only to the extent that the capital gain is subject to taxation.

Example: If the capital gain benefits from a 95% exemption under the PEX regime, the directly attributable ancillary costs are deductible only up to 5%, corresponding to the taxable portion.