by A&P, Piero Aicardi, Maria Edvige Chiari, Achille Mazzanti | 22 May, 2026 | Publications
Aicardi & Partners contributed to the third edition of the book “The Role of the Expert in Negotiated Crisis Composition Proceedings”, published by G. Giappichelli Editore, with two chapters focused on the operational aspects of negotiated crisis composition...
by A&P, Fabrizio Ricci | 21 May, 2026 | Publications
Italian Supreme Court order no. 3728/2026 addresses the abuse of the corporate veil, confirming the broad scope of Article 37(3) of Presidential Decree no. 600/1973, which encompasses both fictitious and genuine interposition. The decision also reiterates the central...
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, Alice Mantovan, Fabrizio Ricci | 16 Apr, 2026 | Publications
The Italian Supreme Court confirms that, pursuant to Article 88(4-ter) of the TUIR, debt discharge gains do not contribute to taxable income where fully offset by tax losses, including carryforwards, within the framework of restructuring agreements under Article...
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, Fabrizio Ricci | 8 Apr, 2026 | Publications
In ruling no. 91/2026, the Agenzia delle Entrate (Italian Revenue Agency) confirms the possibility of applying differentiated share premiums in share-for-share contributions under the controlled realisation regime, where shareholders have non-homogeneous tax bases....
