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NEWS
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, thereby necessitating the application of the withholding tax [...]
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 a service rendered to the payer and is [...]
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 the property in the last municipality of residence [...]
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 Undertaxed Profit or Payment Rule, or the Qualified [...]
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 overridden by the rules preventing double taxation contained [...]
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, thereby granting the right to VAT deduction. However, [...]