by A&P, Matteo Aicardi | 29 Sep, 2026 | Publications
Decision no. 413/2/2026 of the Brescia First-Instance Tax Court recognises the right to a foreign tax credit in respect of capital gains arising from the disposal of foreign shareholdings by individuals and subject in Italy to the mandatory 26% substitute tax. The...
by A&P | 29 Sep, 2026 | Publications
Decision no. 48/2/2026 addresses, apparently for the first time since the entry into force of Article 6-bis of Law no. 212/2000, the consequences of serving a tax assessment notice before the expiry of the 60-day period following notification of the draft assessment,...
by A&P, Matteo Aicardi | 6 Aug, 2026 | Publications
Italian Constitutional Court Decision No. 153/2026 addresses the application of IRAP to professional associations, with specific reference to notarial associations. According to the Court, the mere existence of a professional association is not sufficient to establish...
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...
by A&P, Matteo Aicardi | 9 Jul, 2026 | Publications
Decision no. 1434/2026 of the Milan First-Instance Tax Court addresses the low-tax jurisdiction requirement for the participation exemption in relation to a capital gain realised upon the liquidation of a foreign subsidiary. The court held that the criteria set out in...
