Europe

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

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