The elimination of tax-suspended reserves in corporate reorganisations

by , , | 8 Jun, 2026 | Publications

A contribution published in Rivista delle Operazioni Straordinarie no. 5/2026 examines the treatment of tax-suspended reserves in corporate reorganisations, with particular focus on potential abuse-of-law issues. Failure to reconstitute the reserve may be regarded as legitimate only where it is a natural consequence of the transaction, rather than the result of a structure specifically designed to eliminate the underlying tax restriction.

Published in Rivista delle Operazioni Straordinarie no. 5/2026 by Euroconference.

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