Italy

On 15 October 2026, the Italian Supreme Court (Corte di Cassazione) issued ordinanza n. 26938, delivering a landmark clarification on the treatment of liabilities in business transfers for registration tax purposes under DPR 131/1986. The ruling establishes that liabilities may reduce the taxable base of the registration tax (imposta di registro) only if they are

On 30 October 2026, the European Court of Justice (ECJ) issued a preliminary ruling clarifying the application of the EU Parent‑Subsidiary Directive (Directive 2011/96/EU) and the concept of “beneficial owner” in the context of anti‑abuse clauses. The case originated from a national court referral under Article 267 TFEU, addressing whether dividends received through a chain

In ordinanza n. 26067 dated 1 October 2026, the tax section of the Italian Supreme Court addressed a critical conflict between the accrual principle (principio di competenza) for corporate income tax (IRES) and the temporal allocation rules for VAT. The Court ruled that these two regimes are autonomous and independent; consequently, the subsequent full declaration

The Italian Supreme Court, in ordinanza n. 26234/2026, delivered a pivotal interpretation of the “Omnibus” decree (Decree-Law 113/2024, converted into Law 143/2024) concerning the presumption of occult dividend distribution in closely-held companies (società a base ristretta). The new legislation narrowed the scope of the presumption: it now triggers only for non-existent costs (costi inesistenti), i.e.,

On 29 October 2026, the Italian Revenue Agency (Agenzia delle Entrate) and the National Social Security Institute (INPS) announced the relaunch of their joint “Insieme per le imprese e le università” roadshow, with the first university stop scheduled for 4 November 2026 at Roma Tre University. This initiative forms part of a broader institutional strategy

On 28 October 2026, the Italian Revenue Agency (Agenzia delle Entrate) issued ruling n. 194/2026 clarifying the tax treatment of free share allocations to employees under the favorable regime provided by Article 1, paragraph 1, of Law Decree 218/1997. The ruling addresses a case where an international group granted the same number of shares to

In ruling n. 193/2026 dated 28 October 2026, the Italian Revenue Agency clarified that a holding company characterized as “dynamic”—i.e., equipped with an organized structure of assets, personnel, and operational functions supporting the group—can qualify as a “business” (azienda) for purposes of the tax-neutral contribution regime under Article 176 of the Consolidated Income Tax Act

The Italian Revenue Agency, in ruling n. 192/2026 dated 27 October 2026, addressed the VAT treatment of demolition and remediation expenses incurred by a SICAF (Società di Investimento Collettivo del Risparmio a Capitalizzazione Fissa) for real estate development projects. The Agency determined that such costs generate a refundable VAT credit when they relate to properties

The Italian National Social Security Institute (INPS) has added two new causali (payment reason codes) to the F24 form for the remittance of contributions destined for bilateral bodies (enti bilaterali) that have signed specific conventions with INPS. The expansion of the code catalog facilitates the correct allocation of payments and improves traceability of funds transferred

The recent Omnibus Decree (Decreto Omnibus) introduced an exception to the access restrictions for the Biennial Preventive Concordato (Concordato Preventivo Biennale – CPB). Previously, professionals carrying out activities both individually and through an association with colleagues were barred if the ISA (Synthetic Reliability Indices) codes differed. The new provision, effective for the 2026 tax period,