Italy

When an SRL’s bank account is seized, a shareholder may pay the company’s taxes using the F24 form with code “80” (accollo). This does not release the company from its tax debt but ensures timely payment to avoid interest and penalties. The procedure requires electronic transmission and specific documentation. Published 8 October 2026. Key Takeaways

The Supreme Court’s United Sections, in judgment No. 24825/2026 dated 8 October 2026, delimited the nullity of standard ABI (Italian Banking Association) clauses in bank guarantees. Nullity applies only to guarantees falling within the 2002-2005 period and of a generic nature. For specific guarantees or those outside that period, the Bank of Italy’s measure alone

The third installment of the series on business property acquisition, dated 8 October 2026, details the accounting treatment: cost includes purchase price and ancillary charges; land must be separated from buildings as non-depreciable. It covers fiscal deductibility, VAT deduction and adjustment mechanisms, and the special tax credit for investments in Special Economic Zones (ZES). Key

The Supreme Court ruled that a de facto credit line (fido di fatto) can be proven without a written contract using bank statements, scalar statements, credit limit registers, and Central Risk Database reports. However, evidence must demonstrate both the existence of the credit facility and its quantitative limit. Decision dated 8 October 2026. Key Takeaways

The Supreme Court outlined criteria for identifying a de facto director (amministratore di fatto): continuous and significant managerial activity, stable integration into the organizational structure, and external representation of the company. Formal appointment is not required. This classification triggers full directorial liability. Ruling dated 8 October 2026. Key Takeaways Behavioral Test: Courts look at actual

The Daily Report of 8 October 2026 announces that starting 2027, municipalities with excessive uncollected tax credits will be required to entrust forced collection to AMCO (Asset Management Company). This centralizes enforcement and aims to improve recovery rates. The measure also addresses constitutional court rulings on unserved notices and introduces a new conformity visa web

Legislative Decree 148/2026 introduces a derogation for cooperative compliance (CPB) renewal: partnerships and associated firms can admit new partners with revenues under 35,000 euros without losing CPB status. Previously, any composition change risked disqualification. The rule aims to support small professional firms. Effective 8 October 2026. Key Takeaways Revenue Threshold: New entrants must have individual

On 7 October 2026, the Australian Taxation Office (ATO) released a ruling confirming that the United States’ Global Intangible Low-Taxed Income (GILTI) and Net Controlled Foreign Income (NCTI) regimes do not qualify as Controlled Foreign Company (CFC) rules for the purposes of Australia’s hybrid mismatch provisions under Division 832 of the Income Tax Assessment Act

On 7 October 2026, Lipani Legal&Tax, an Italian law firm with a dedicated tax practice, announced the hiring of Antonino Castorino and Nicola Azzariti as Associates and the return of Jacopo Fronticelli. The appointments strengthen the firm’s administrative law, energy regulation, and public procurement capabilities, complementing its existing tax advisory services for infrastructure and energy

On 6 October 2026, the Revenue Agency released the much-anticipated guiding circular (Circolare n. 18/E) on the Biennial Preventive Concordat (CPB) for the 2026-2027 tax period. The circular provides comprehensive instructions on eligibility criteria, the determination of the concordat income proposal, the adhesion process, and the effects on tax assessments. The deadline for submitting the