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...

Inheritance tax exemption and estate co-ownership: control cannot be established by combining jointly held and individually owned interests

by A&P, Fabrizio Ricci | 10 Jun, 2026 | Publications

Italian Revenue Agency Ruling No. 109/2026 clarifies that, for the purposes of the inheritance and gift tax exemption, shareholdings transferred mortis causa and held jointly by the heirs cannot be combined with interests already owned individually by them in order to...

The elimination of tax-suspended reserves in corporate reorganisations

by A&P, Matteo Aicardi, Fabrizio Ricci | 8 Jun, 2026 | Publications

A contribution published in Rivista delle Operazioni Straordinarie no. 5/2026 examines the treatment of tax-suspended reserves in corporate reorganisations, with particular focus on potential abuse-of-law issues. Failure to reconstitute the reserve may be regarded as...