Europe

In a landmark ruling dated 10 August 2026, the Italian Supreme Court (Cassazione, Sez. V, Ord. 19092/2026) clarified that the mere ownership of real estate, bank accounts, or family ties in Italy does not, by itself, constitute sufficient evidence to rebut a taxpayer’s claim of foreign tax residence. The decision reinforces the principle that tax

Recent European Court of Justice (ECJ) jurisprudence, as analyzed in Il Sole 24 Ore on 17 August 2026, confirms that the VAT triangulation simplification regime (Article 138 of Directive 2006/112/EC) can apply to supply chains involving four operators, provided the contractual and transport conditions are met. Traditionally, triangulation required three parties: a supplier in Member

According to analysis published in Il Sole 24 Ore on 17 August 2026, the promoter of a chain sale (vendita a catena) bears significant VAT risk if the operational conditions for triangulation simplification are not meticulously satisfied. A chain sale involves multiple consecutive supplies of the same goods while in transit from the original supplier

The Regional Tax Commission of Puglia (CGT II grado, Sez. 26, Sentenza n. 1045/2026, March 2026) ruled that a trust endowment deed (atto di dotazione) transferring real estate into a trust qualifies for the fixed registration tax (imposta fissa di registro) of €200, rather than the proportional rate based on property value. The decision interprets

Decree Delegated No. 116, dated 10 August 2026, implements the legal framework for Advance Pricing Agreements (APAs) between San Marino and Italy, following the bilateral agreement signed in July 2026. The decree establishes procedures for San Marino multinational enterprises to obtain binding rulings on transfer pricing methodologies for cross-border transactions with Italian associated enterprises. This

Effective from late 2026, Italian citizens residing abroad for more than 12 months must enroll in the Registry of Italians Resident Abroad (AIRE – Anagrafe degli Italiani Residenti all’Estero), as highlighted in Il Sole 24 Ore on 31 August 2026. This requirement stems from Law No. 470/1988 and recent implementing decrees linking AIRE registration to