The draft corrective decree implementing the Italian tax reform, known as the “Omnibus Decree”, introduces changes to the rules governing share contributions under the controlled realisation regime where the transaction results in a tax loss, i.e. where the increase in the equity of the receiving company is lower than the contributor’s tax basis in the contributed shares. The article examines the amendments set out in the draft decree, which received preliminary approval from the Italian Council of Ministers on 10 June 2026 and, at the time of publication, was awaiting the non-binding opinion of the relevant parliamentary committees.
Published in Euroconference News.
