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 [...]
Web Tax: Declaration Deadline by June 30, 2025
June 30 marks the deadline for filing the web tax declaration for the 2024 tax period. This obligation concerns the self-assessment of the tax due on digital [...]
Employee participation in company management
The law on employee participation in company management, capital, and profits – definitively approved by the Senate on 14 May 2025 – is pending publication in the [...]
Surface rights: Tax regime of proceeds
The Italian Revenue Agency, in its response no. 129 dated May 13, 2025, clarified that proceeds from the transfer of surface rights alone are classified as miscellaneous [...]
Taxes definitively paid abroad
Taxes paid abroad entitle the taxpayer to a foreign tax credit under Article 165 of the Italian Income Tax Code (TUIR), provided that: They relate to income [...]