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 [...]
Company VAT debts: Director liable if due diligence not exercised
A company director is jointly liable for the payment of VAT debts if no insolvency petition has been filed – unless they can prove that they managed [...]
Capital Gain realised under the PEX regime both in Italy and in France – Deduction of taxes paid in France
The response to ruling request No. 101 issued by the Italian Revenue Agency on 15 April 2025 confirmed the application of Article 165(10) of the TUIR to [...]
Capital gains subject to PEX – Participation Exemption – partial exemption and related tax credit
In its Reply No. 101 of 15 April 2025, the Italian Revenue Agency provided clarifications regarding the tax credit on tax paid in France in relation to [...]
Transfer of shareholdings: PEX regime for non-EU companies
On April 9, 2025, the Italian Association of Chartered Accountants (AIDC) published Interpretation No. 229 regarding the application of the PEX regime to capital gains from the [...]