In its ruling of 25 August 2025, No. 23842, the Court of Cassation endorsed the view that the artificial relocation of a company\u2019s registered office abroad constitutes an abusive practice that cannot be challenged in the absence of a purely artificial arrangement, where the company actually carries out an effective economic activity abroad.<\/p>\n
In the present case, the company under scrutiny had always made use of its office in Madeira, where its registered office is located, as well as tugboats and non-Italian employees; meetings of the Board of Directors and shareholders\u2019 meetings had always been held abroad. Furthermore, weight was given to the fact that the activity, being geographically carried out in areas (the Atlantic Ocean) adjacent to Madeira, was presumed to have actually been performed on site.<\/p>\n
In light of these circumstances, the Supreme Court found the tax authority\u2019s objection regarding the alleged presence of de facto directors in Italy to be unfounded.<\/p>\n","protected":false},"excerpt":{"rendered":"
In its ruling of 25 August 2025, No. 23842, the Court of Cassation endorsed the view that the artificial relocation of a company\u2019s registered office abroad constitutes an abusive practice that cannot be challenged in the absence of a purely artificial arrangement, where the company actually carries out an effective economic activity abroad. In the […]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"inline_featured_image":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-3191","post","type-post","status-publish","format-standard","hentry","category-unkategorisiert"],"yoast_head":"\n