by A&P, Fabrizio Ricci | 19 Mar, 2026 | Publications
In case C-828/24, the Court of Justice of the European Union confirms that the withholding tax exemption on cross-border interest and royalties under the Interest and Royalties Directive must be assessed on a substantive rather than procedural basis. Accordingly, the...
by A&P, Fabrizio Ricci, Valentina Sanchi | 5 Mar, 2026 | No Catgory
The General Court of the European Union holds that the right to deduct VAT must be exercised in the period in which it arises, even if the invoice is received in the following year, provided that it is obtained before the deadline for filing the annual VAT return....
by A&P, Matteo Aicardi, Fabrizio Ricci | 3 Mar, 2026 | Publications
The recent reopening of the tax-favoured conversion regime into a simple partnership provides a significant opportunity to extract real estate assets no longer instrumental to the business at more favourable tax conditions. However, where the transaction is followed...
by A&P, Matteo Aicardi, Fabrizio Ricci | 17 Oct, 2025 | Publications
A contribution published in il fisco – Wolters Kluwer no. 41/2025 examines some of the key issues still surrounding tax-suspended reserves, with particular focus on the possible existence of an ordering rule governing their utilisation and the impact of...
by A&P, Matteo Aicardi, Fabrizio Ricci | 22 Sep, 2025 | Publications
A contribution published in il fisco – Wolters Kluwer no. 37/2025 examines the corporate, accounting and tax implications of an accounting-negative demerger through spin-off. The analysis addresses a transaction of growing practical relevance, highlighting...
