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...
by A&P, Matteo Aicardi, Fabrizio Ricci | 28 May, 2026 | Publications
A contribution published in IPSOA Quotidiano examines Italian Revenue Agency Ruling No. 90/2026, which for the first time addresses the tax treatment of profit distributions made on a basis that is disproportionate to shareholders’ equity interests. According to...
by A&P, Matteo Aicardi | 21 May, 2026 | Publications
Italian Supreme Court order no. 13128/2026 clarifies that the late receipt of a certificate issued by the foreign tax authority does not preclude the withholding tax exemption on EU dividends under Article 27-bis of Presidential Decree no. 600/1973, provided that the...
by A&P, Matteo Aicardi | 21 May, 2026 | Publications
With order no. 3591/2026, the Italian Supreme Court reaffirms, in the context of corporate tax residency (so-called esterovestizione), that the decisive criterion under Article 73(3) of the TUIR is the place where the entity’s effective management and decision-making...
by A&P, Giulia Geminiani, Matteo Aicardi | 8 May, 2026 | Publications
Article 3 of Decree-Law no. 38/2026 introduces a specific tax regime for negative goodwill recognised by IAS adopters in business transfer transactions. The amount recognised in the income statement is included in the IRES and IRAP tax base in five equal annual...
