News, events and publications
News & Events
Negotiated crisis composition: the new ministerial decree reshapes the restructuring plan
In the IUSPod Key Talks podcast by La Scala Società tra Avvocati, Achille Mazzanti and Luca Scaccaglia discuss the key...
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Human and technological capital: Filippo Forlani speaks at the Politecnico di Milano Professional Firms Observatory conference
Filippo Forlani, Partner at Aicardi & Partners, participated as a speaker at the conference "Human and Technological Capital: The Future...
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Aicardi & Partners financial and tax advisor in the launch of Vivaldi Group
Aicardi & Partners advised the sellers of the target companies on the financial and tax aspects of the transaction that...
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Aicardi & Partners financial advisor in a bankruptcy arrangement under Article 124 of the Italian Bankruptcy Law
Aicardi & Partners advised Selvi Srl, acting as financial advisor, in the submission of a bankruptcy arrangement proposal under Article...
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Aicardi & Partners together with C-Oralia and D-Entity in the merger by incorporation into Nexxta S.p.A.
D-Entity S.r.l. and C-Oralia S.r.l., two leading companies in the Italian dental technology sector, have launched their expansion project through...
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Business transfers in negotiated crisis composition: Achille Mazzanti featured on IUSPod Key Talks
Achille Mazzanti was featured on IUSPod Key Talks, the podcast series by La Scala Società tra Avvocati, discussing business transfers...
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Creditworthiness and restructuring tools under the Italian Insolvency Code
On April 30, 2026, an event was held in Bologna focusing on the role of creditworthiness in restructuring processes and...
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Advisors to Gevorkyan on the acquisition of Sinteris Industria Prodotti Sinterizzati
Gevorkyan has acquired Sinteris Industria Prodotti Sinterizzati through a pre-pack sale under Article 22 of the Italian Insolvency Code, within...
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Master “Business Crisis”: an operational focus on the tools of the Italian Insolvency Code
The professionals of Aicardi & Partners are also taking part in the second edition of the Master’s program “Business Crisis,”...
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Real Estate | Debt restructuring through a certified recovery plan under Article 56 of the Italian Insolvency Code
Aicardi & Partners advised a real estate company based in the Forlì area on the restructuring of over €4.5 million...
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Aicardi & Partners in the negotiated restructuring of a leading Emilia-Romagna-based retail company (GDO)
The negotiated crisis composition procedure of an Emilia-Romagna-based company operating in the large-scale retail (GDO) sector has been successfully completed,...
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Aicardi & Partners advised on the acquisition of 2G
Aicardi & Partners acted as accounting and tax advisor to Unigrains Italia and the other shareholders of Gruppo Vivaldi in...
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Business continuity and liability: Piero Aicardi speaker at the APRI National Conference
Piero Aicardi took part as a speaker at the APRI National Conference focused on business continuity and liability in restructuring...
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Tax settlement confirmed within liquidation-based composition with creditors proceedings
Aicardi & Partners successfully completed a tax settlement under Article 88 of the Italian Insolvency Code within liquidation-based composition proceedings...
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Aicardi & Partners advisor fiscale nella cessione di People Design a Koinos Capital
Aicardi & Partners advised the sellers of People Design on the tax aspects of the transaction through which Koinos Capital,...
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Aicardi & Partners financial and legal advisor to IMA Group in the acquisition of a business unit of Sarong
Aicardi & Partners advised IMA Group on the financial and legal aspects of the acquisition of the business unit comprising...
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Aicardi & Partners financial and tax advisor in the sale of Parma Promenade shopping centre
Aicardi & Partners advised the seller, C-Holding, on the financial and tax aspects of the sale of 100% of the...
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Aicardi & Partners financial and tax advisor in the sale of a controlling stake in Gruppo Ranocchi to Zucchetti
Aicardi & Partners advised the selling shareholders on the financial and tax aspects of the transaction through which Zucchetti acquired...
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Aicardi & Partners in Italpizza’s acquisition of the Mantua Surgelati business unit
Aicardi & Partners advised Italpizza in the acquisition of the Mantua Surgelati business unit through a competitive auction process held...
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Piero Aicardi acts as independent expert in the Officine Maccaferri going-concern composition proceedings
The Court of Bologna approved the going-concern composition with creditors of Officine Maccaferri, marking a key milestone in the group’s...
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Publications
PEX capital gains: the ETR test for pre-ATAD tax years
Decision no. 1434/2026 of the Milan First-Instance Tax Court addresses the low-tax jurisdiction requirement for the participation exemption in relation...
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Source-state taxation of loss-making non-resident taxpayers
The Advocate General’s Opinion in Case C-241/25 confirms the Court of Justice of the European Union’s case law holding that...
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Interest expense, business purpose and economic reasonableness: the Italian Supreme Court requires a quantitative and comparative assessment by the tax authority
Italian Supreme Court decision no. 19140/2026 clarifies that the deductibility of interest expense for IRES purposes does not require a...
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Interim financial statements and adequate organisational structures: the systemic impact of the new OIC 30
A contribution published in Bilancio, vigilanza e controlli no. 6/2026 examines the role of interim financial statements prepared under the...
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Registration tax on shareholder loans referred to in a demerger deed
Italian Supreme Court order no. 17920/2026 confirms that a shareholder loan referred to in a demerger deed is subject to...
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Failure to file an income tax return: foreign tax credit available where a double taxation treaty applies
Italian Supreme Court order no. 16134/2026 clarifies that, where a double taxation treaty requires Italy to eliminate double taxation, the...
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Inheritance tax exemption and estate co-ownership: control cannot be established by combining jointly held and individually owned interests
Italian Revenue Agency Ruling No. 109/2026 clarifies that, for the purposes of the inheritance and gift tax exemption, shareholdings transferred...
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Approval timing for financial statements in distressed companies
A contribution published in Bilancio, vigilanza e controlli no. 5/2026 examines the timing for the approval of financial statements in...
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The elimination of tax-suspended reserves in corporate reorganisations
A contribution published in Rivista delle Operazioni Straordinarie no. 5/2026 examines the treatment of tax-suspended reserves in corporate reorganisations, with...
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Disproportionate profit distributions: strengths and weaknesses of Italian Revenue Agency Ruling No. 90/2026
A contribution published in IPSOA Quotidiano examines Italian Revenue Agency Ruling No. 90/2026, which for the first time addresses the...
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Third edition of the book “The Role of the Expert in Negotiated Crisis Composition Proceedings”
Aicardi & Partners contributed to the third edition of the book “The Role of the Expert in Negotiated Crisis Composition...
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Late-issued certificates and the Parent-Subsidiary exemption: the Italian Supreme Court confirms a substance-over-form approach
Italian Supreme Court order no. 13128/2026 clarifies that the late receipt of a certificate issued by the foreign tax authority...
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Abuse of the corporate veil: burden of proof and scope of anti-avoidance measures
Italian Supreme Court order no. 3728/2026 addresses the abuse of the corporate veil, confirming the broad scope of Article 37(3)...
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Assignee of the receivable not entitled to issue a credit note
In case T-233/25, the General Court of the European Union clarifies that the right to reduce the VAT taxable amount...
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Corporate tax residency: the Italian Supreme Court reaffirms the centrality of the place of effective management
With order no. 3591/2026, the Italian Supreme Court reaffirms, in the context of corporate tax residency (so-called esterovestizione), that the...
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Participation exemption: abusive classification as a financial fixed asset of a shareholding already agreed for sale
The Italian Supreme Court addresses the requirements for the application of the participation exemption under Article 87 of the TUIR,...
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ax treatment of negative goodwill for IAS adopters: the new timing rule
Article 3 of Decree-Law no. 38/2026 introduces a specific tax regime for negative goodwill recognised by IAS adopters in business...
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Corporate tax residency, effective establishment and VAT territoriality: the Italian Supreme Court’s position
Italian Supreme Court decisions nos. 7692/2026, 7694/2026 and 8714/2026 address corporate tax residency issues with specific reference to the VAT...
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Contributions for future capital increases: limits on anti-avoidance recharacterisation
Italian Supreme Court decision no. 8255/2026 addresses the potential recharacterisation of contributions for future capital increases as intragroup loans for...
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Debt discharge gains: tax neutrality where offset by tax losses
The Italian Supreme Court confirms that, pursuant to Article 88(4-ter) of the TUIR, debt discharge gains do not contribute to...
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PEX regime and the business activity requirement: the Italian Supreme Court narrows the scope for development companies
The Italian Supreme Court, in decision no. 6732/2026, narrows the scope of the PEX regime with respect to the business...
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Transfer of shareholdings under the controlled realisation regime: differentiated share premiums in the presence of “misaligned” tax bases
In ruling no. 91/2026, the Agenzia delle Entrate (Italian Revenue Agency) confirms the possibility of applying differentiated share premiums in...
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No gift tax exemption where the usufructuary retains voting rights on profit distributions
With twin decisions no. 6614/2026 and no. 6616/2026, the Italian Supreme Court denies the inheritance and gift tax exemption in...
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Transfer of Equity Interests and Control Requirements
Matteo Aicardi analyzes Italian Supreme Court decision no. 6799/2026 on the inheritance and gift tax exemption under Article 3(4-ter) of...
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Cross-border interest and royalties: a substance-over-form approach to withholding tax exemption
In case C-828/24, the Court of Justice of the European Union confirms that the withholding tax exemption on cross-border interest...
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Tax-favoured conversion into a simple partnership at risk of abuse if followed by a real estate disposal
The recent reopening of the tax-favoured conversion regime into a simple partnership provides a significant opportunity to extract real estate...
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Tax-suspended reserves: handle with care
A contribution published in il fisco - Wolters Kluwer no. 41/2025 examines some of the key issues still surrounding tax-suspended...
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Accounting-negative demerger through spin-off
A contribution published in il fisco - Wolters Kluwer no. 37/2025 examines the corporate, accounting and tax implications of an...
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