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 | 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...