Global Minimum Tax and Reporting Obligations
With the publication of the Ministerial Decree (DM) of 7 November 2025 a new tax return model has been introduced concerning the global minimum tax for large [...]
Tax neutrality for income tax purposes in the case of contribution of shareholdings to a holding company
When the recipient company does not acquire control of another company pursuant to Article 2359, paragraph 1, no. 1) of the Italian Civil Code, nor increases its [...]
Transactions carried out by the foreign parent company – Italian permanent establishment not involved in the transactions – VAT refund
In its ruling of 13 February 2025, No. 33, the Italian Revenue Agency examined the procedures for recovering the deductible VAT surplus, by means of a refund [...]
VAT Exemption for Intra-Community Supply Followed by Export Outside the EU
The Court of Justice of the European Union (CJEU), in judgment C-602/24 of 1 August 2025, clarified that a supply of goods initially declared as an intra-Community [...]
Interest on shareholder loans – Territoriality criteria and taxation methods
Capital income is taxable for non-residents when paid by persons resident in Italy; therefore, interest on loans granted by non-resident entities to Italian companies is territorially taxable [...]
Companies can obtain an IRAP refund on dividends
Companies can obtain an IRAP refund on dividends, thereby overcoming national practice and strengthening the application of EU directives. This was established by Judgment No. 681 of [...]
Extraordinary cross-border transactions – Cross-border and international demergers – Updates introduced by Legislative Decree 88/2025
Legislative Decree 88/2025 introduced some amendments to the rules governing extraordinary cross-border and international transactions. With regard to demergers, the amendments did not affect the procedure itself [...]
Rental via digital platforms: no withholding tax
The commissions received by digital platforms for the rental of goods are not subject to the withholding tax provided for under Art. 25-bis of Presidential Decree 600/73.The [...]
Disposals of shareholdings after change of residence – Treaty regime
Several tax treaties concluded by Italy provide that the former country of residence of the individual may exercise its taxing rights on capital gains from shareholdings realized [...]