Income arising from the write-off of liabilities: when is the extinguishment of a debt (actually) taxable?

by A&P, Fabrizio Ricci | 30 Jul, 2026 | Publications

Italian Supreme Court Order No. 23218/2026 provides an opportunity to examine the tax treatment of liabilities assumed as part of a business acquisition and subsequently written off, and, more broadly, the circumstances in which the extinguishment of a liability gives...

by A&P, Fabrizio Ricci | 24 Jul, 2026 | Publications

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...

Source-state taxation of loss-making non-resident taxpayers

by A&P, Fabrizio Ricci | 2 Jul, 2026 | Publications

The Advocate General’s Opinion in Case C-241/25 confirms the Court of Justice of the European Union’s case law holding that a definitive withholding tax on dividends paid to loss-making non-resident companies is incompatible with the free movement of capital where the...

Interim financial statements and adequate organisational structures: the systemic impact of the new OIC 30

by A&P, Francesco Carlo Vancini, Fabrizio Ricci | 20 Jun, 2026 | Publications

A contribution published in Bilancio, vigilanza e controlli no. 6/2026 examines the role of interim financial statements prepared under the new OIC 30 within the framework of adequate organisational, administrative and accounting structures. In addition to updating...

Registration tax on shareholder loans referred to in a demerger deed

by A&P, Fabrizio Ricci | 18 Jun, 2026 | Publications

Italian Supreme Court order no. 17920/2026 confirms that a shareholder loan referred to in a demerger deed is subject to proportional registration tax. The ruling reiterates that the requirement concerning the identity of the parties must be interpreted broadly and...