by A&P, Fabrizio Ricci | 18 Jun, 2026 | Publications
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...
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...
by A&P, Fabrizio Ricci | 14 May, 2026 | Publications
The Italian Supreme Court addresses the requirements for the application of the participation exemption under Article 87 of the TUIR, with particular reference to the classification of the shareholding as a financial fixed asset in the first financial statements...
