Italy

The Italian Revenue Agency’s Ruling No. 165/2026, published on 23 October 2026, clarifies the tax treatment of Italian-resident beneficiaries of transparent foreign trusts. Under the ruling, income generated by a trust considered transparent under the laws of its jurisdiction of establishment is attributed to the Italian beneficiary proportionally to their beneficial interest, irrespective of whether

On 26 October 2026, the Italian Revenue Agency (Agenzia delle Entrate) published ruling no. 189/2026, confirming that fuel vouchers granted as corporate welfare to employees performing Sunday shifts in essential public services qualify as fringe benefits excluded from taxable income. The ruling addresses a company entrusted with uninterrupted essential public services organized seven days a

The Italian Supreme Court (Cassazione) in Judgment No. 36078/2026, filed 23 October 2026, established that the VAT conformity visa (visto di conformità) does not automatically absolve a company’s legal representative from criminal liability for improper VAT offsetting (indebita compensazione). The Court ruled that reliance on a tax professional’s certification must be assessed alongside the director’s

A comprehensive analysis published on 26 October 2026 examines the evolving jurisprudence on abuse of law (abuso del diritto) under Article 10-bis of Law 212/2000 (Statuto del Contribuente). The article delineates the necessary conditions for tax authorities to invoke the abuse doctrine: (i) existence of one or more operations lacking economic substance, (ii) achievement of

The Italian Supreme Court (Cassazione) issued a landmark ruling on 24 October 2026 confirming that undistributed profits allocated to reserves in non-transparent SRLs (limited liability companies) are excluded from the INPS contribution base for working partners (soci lavoratori). The decision resolves a long-standing dispute between the National Social Security Institute (INPS) and taxpayers, who argued

Effective from the 2026 tax year, the annual deductibility ceiling for contributions to complementary pension schemes (fondi pensione complementari) has been raised from €5,164.57 to €5,300. The increase, confirmed by the Revenue Agency in October 2026, applies to the aggregate of employee voluntary contributions, employer contributions, and any additional voluntary payments. Notably, the maturing TFR

The deadline for ISCRO 2026 (Indennità Straordinaria di Continuità Reddituale e Operativa) applications is 31 October 2026. This income support measure targets self-employed workers enrolled in the INPS Separate Management (Gestione Separata) who have experienced a significant earnings decline. Eligibility requires that 2025 net income be less than 70% of the average net income for

An analysis dated 23 October 2026 explores the tax implications of asymmetric splits (scissione asimmetrica) of simple partnerships (società semplici) under Article 173 of the Consolidated Income Tax Act (TUIR). This reorganization tool allows the separation of real estate or participatory assets into distinct entities, facilitating generational succession and asset protection. The operation can qualify

The Italian Supreme Court (Cassazione) in Judgment No. 26277/2026, published 22 October 2026, ruled that the five-year holding period exemption for real estate capital gains (Article 67, TUIR) survives demolition and reconstruction of a building. The case involved a taxpayer who demolished a property held for over five years, reconstructed a new building on the

On 23 October 2026, the Director of the Italian Revenue Agency signed a measure defining the modalities and terms for accessing the special voluntary disclosure (ravvedimento speciale) provided by Article 29 of Legislative Decree no. 148/2026. This regime allows taxpayers who have adhered to the biennial preventive concordato (concordato preventivo biennale) for the 2024-2025 period