Chairman of the Board of Directors – Compatibility in the presence of an employment relationship – incompatibility
Recently, the Court of Cassation, in Order No. 5318/2025, ruled that there is an absolute incompatibility between the status of an employee of a company limited by [...]
One-Coupon” Bonds: no abuse in the timing mismatch
In its ruling of 1 December 2025, No. 299, the Italian Revenue Agency provided clarification regarding abuse of law in connection with “one-coupon” bonds where there is [...]
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 [...]