In ruling no. 91/2026, the Agenzia delle Entrate (Italian Revenue Agency) confirms the possibility of applying differentiated share premiums in share-for-share contributions under the controlled realisation regime, where shareholders have non-homogeneous tax bases. This approach allows the avoidance of taxable gains or losses and supports “induced neutrality”, with significant practical implications for group reorganisations and succession planning.
Published in Euroconference News.
