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 [...]
Artificial economic activity abroad – Non-existence
In its ruling of 25 August 2025, No. 23842, the Court of Cassation endorsed the view that the artificial relocation of a company’s registered office abroad constitutes [...]
Intra-EU Supply with Extra-EU Transport: VAT Exemption
A supply of goods initially declared by the supplier as an intra-EU transaction, but which – without the supplier’s knowledge – was transported by the purchaser outside [...]
Parent Company Transactions – Direct Involvement of the Permanent Establishment – Conditions (Italian Tax Authority Ruling No. 193 of July 24, 2025)
he ruling issued by the Italian Tax Authority (Agenzia delle Entrate) on July 24, 2025, No. 193, analyzes the conditions under which the permanent establishment of a [...]
Dividends: Waiver does not generate taxable income for the investee company
The waiver of dividends by individual shareholders who are not entrepreneurs does not generate taxable extraordinary income for the investee company, as the shareholders’ receivable corresponds to [...]
Exit Tax and Branch Exemption Regime: Transfer of Tax Residence Abroad
In the case of companies that exercise the branch exemption (BEX) option and transfer their tax residence abroad, the capital gain relating to the foreign permanent establishment [...]