Withholding tax on dividends received by a non-resident pension fund
n judgment C-525/24 of 27 November 2025, the Court of Justice of the EU clarified issues concerning non-resident pension funds and corporate income tax on dividends. The [...]
Donation of businesses or shareholdings – Gift tax – Exemption for donations of shareholdings or businesses in favour of the donor’s spouse or descendant
A deed concerning the donation of shareholdings or businesses to the donor’s spouse or descendant, provided it meets the exemption requirements set out in Article 3, paragraph [...]
Retired persons relocating to Southern Italy, 7 % flat tax also applicable to the liquidation of a foreign company
Extraordinary transactions, such as winding up corporate vehicles abroad, may also benefit from the lump-sum substitute tax regime. The reply to ruling request 292/2025 issued by the [...]
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 [...]