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 role of the tax authority’s burden of proof in applying the specific anti-avoidance provision.
Published in La Circolare Tributaria no. 10/2026 Euroconference.
