Contributions of Shareholdings in EU Entities – Tax Neutrality
Legislative Decree No. 192/2024, reforming IRPEF and IRES, has extended the subjective scope of application of Article 177(2) of the TUIR, which governs the so-called "controlled realisation" [...]
Waiver of Dividends – Legal Receipt – Application of the 26% Withholding Tax under Article 27 of DPR 600/73
In its response to ruling request No. 59/2025, the Italian Revenue Agency states that a waiver by individual shareholders of dividends already declared constitutes their legal receipt, [...]
The payment of a subsidy is not included in the VAT taxable amount
A subsequent compensation for financial losses, determined not on the basis of the number of users, but on a lump sum basis, does not constitute consideration for [...]
First Home Purchase: Non-Resident and Sale Within Five Years
The Italian Revenue Agency (Agenzia delle Entrate), with replies No. 28 and No. 29 of 12 February 2025, clarified that a non-resident is not required to purchase [...]
Global Minimum Tax: Updated list of qualified jurisdictions
OECD published the updated list of countries, including Italy (with 15 %), that have obtained the transitional status of qualified legislation concerning the Income Inclusion Rule, the [...]
Foreign income that partially contributes to the total taxable income – Reduction of foreign tax – Compatibility with Double Taxation Conventions – Jurisprudential guidelines
The provision of the TUIR, which requires a proportional reduction of the deductible foreign tax when foreign income only partially contributes to the taxable base, could be [...]
VAT: Deduction for Holding Companies with Active Management Interference
In line with EU case law, the interference of a holding company in the management of the companies in which it holds shares constitutes an economic activity, [...]
Spin-off of Companies and Subsequent Transfer of the Acquired Participation – No Tax Abuse – New Provisions According to Legislative Decree 192/2024
According to the new paragraph 15-quater of Article 173 of the Consolidated Income Tax Act, the spin-off of a company and the subsequent transfer of the acquired [...]
Dividend washing: cases of disapplication of the contrasting rules
The Italian Revenue Agency (Agenzia delle Entrate), by means of its reply No. 8 of 21 January 2025, has ruled on the issue of dividend washing: According [...]