by A&P, Matteo Aicardi | 7 May, 2026 | Publications
Italian Supreme Court decisions nos. 7692/2026, 7694/2026 and 8714/2026 address corporate tax residency issues with specific reference to the VAT place-of-supply rules applicable to B2B services. The Court clarifies that identifying the centre of management or the...
by A&P, Matteo Aicardi | 9 Apr, 2026 | Publications
The Italian Supreme Court, in decision no. 6732/2026, narrows the scope of the PEX regime with respect to the business activity requirement. In particular, the Court excludes that activities typical of the early stages of real estate development – such as asset...
by A&P, Matteo Aicardi | 23 Mar, 2026 | Publications
Matteo Aicardi analyzes Italian Supreme Court decision no. 6799/2026 on the inheritance and gift tax exemption under Article 3(4-ter) of the TUSD. The ruling confirms a strictly formal interpretation of the control requirement, limited to legal control under Article...
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...
