by A&P, Matteo Aicardi | 9 Jul, 2026 | Publications
Decision no. 1434/2026 of the Milan First-Instance Tax Court addresses the low-tax jurisdiction requirement for the participation exemption in relation to a capital gain realised upon the liquidation of a foreign subsidiary. The court held that the criteria set out in...
by A&P, Fabrizio Ricci | 28 May, 2026 | No Catgory
Decision no. 50/1/2026 of the Bergamo First-Instance Tax Court addresses the application of the general anti-abuse rule to share contributions carried out under the controlled realisation regime pursuant to Article 177(2) of the TUIR. The ruling raises critical issues...
