Italy: Italy Shareholder Loans vs Hidden Revenues: Bank Transfer Insufficient Proof
On 2 October 2026, the Italian Supreme Court (Corte di Cassazione) reaffirmed that mere bank traceability (bonifico) of funds from a shareholder to the company is insufficient to prove that a shareholder loan (finanziamento soci) is genuine and not a disguised distribution of hidden revenues (ricavi occulti). The Court requires a holistic assessment of: (1)
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