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Inheritance tax exemption and estate co-ownership: control cannot be established by combining jointly held and individually owned interests

Inheritance tax exemption and estate co-ownership: control cannot be established by combining jointly held and individually owned interests

by A&P, Fabrizio Ricci | 10 Jun, 2026 | Publications

Italian Revenue Agency Ruling No. 109/2026 clarifies that, for the purposes of the inheritance and gift tax exemption, shareholdings transferred mortis causa and held jointly by the heirs cannot be combined with interests already owned individually by them in order to...
Approval timing for financial statements in distressed companies

Approval timing for financial statements in distressed companies

by A&P, Achille Mazzanti | 10 Jun, 2026 | Publications

A contribution published in Bilancio, vigilanza e controlli no. 5/2026 examines the timing for the approval of financial statements in distressed companies, focusing on the relationship between statutory deadlines, the going concern assumption and the quality of...
The elimination of tax-suspended reserves in corporate reorganisations

The elimination of tax-suspended reserves in corporate reorganisations

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...
Disproportionate profit distributions: strengths and weaknesses of Italian Revenue Agency Ruling No. 90/2026

Disproportionate profit distributions: strengths and weaknesses of Italian Revenue Agency Ruling No. 90/2026

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...
Third edition of the book “The Role of the Expert in Negotiated Crisis Composition Proceedings”

Third edition of the book “The Role of the Expert in Negotiated Crisis Composition Proceedings”

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...
Late-issued certificates and the Parent-Subsidiary exemption: the Italian Supreme Court confirms a substance-over-form approach

Late-issued certificates and the Parent-Subsidiary exemption: the Italian Supreme Court confirms a substance-over-form approach

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...
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Articoli recenti

  • Negotiated crisis composition: the new ministerial decree reshapes the restructuring plan
  • PEX capital gains: the ETR test for pre-ATAD tax years
  • Human and technological capital: Filippo Forlani speaks at the Politecnico di Milano Professional Firms Observatory conference
  • Source-state taxation of loss-making non-resident taxpayers
  • Interest expense, business purpose and economic reasonableness: the Italian Supreme Court requires a quantitative and comparative assessment by the tax authority

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ABOUT

Who we are

The firm

Areas of practice

News

Carreer

Contact us

Bologna:

Via Dante, 26 – 40125 Bologna

Tel. +39 051 349627
+39 051 342674
Fax. +39 051 391564
posta@aicardiepartners.it

Milan:

Piazza Del Liberty, 8 – 20121 Milan

Tel. +39 02 86998023

Fax. +39 02 86915457

posta@aicardiepartners.it

Rimini:

Via Soardi, 5 –  47921 Rimini
Tel. +39 051 349627

Fax. +39 051 342674

posta@aicardiepartners.it

Privacy Policy | Cookie Policy

V.A.T. 03744881206

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