Italian Supreme Court order no. 17920/2026 confirms that a shareholder loan referred to in a demerger deed is subject to proportional registration tax. The ruling reiterates that the requirement concerning the identity of the parties must be interpreted broadly and substantively, consistently with the principles established by the Joint Divisions of the Italian Supreme Court in decision no. 14432/2023.
Published in La Circolare Tributaria no. 26/2026 by Euroconference.
