Luigi Belluzzo, Ivan Mastrototaro and Gise Genco, in Fiscalità & Commercio Internazionale No. 3/2026 published by Wolters Kluwer, analyse the changes introduced by Legislative Decrees No. 192/2024 and No. 192/2025 concerning share exchanges through contribution and the controlled realisation regime under Article 177 of the Italian Income Tax Code (T.U.I.R.).
Among the topics discussed are: the expansion of the subjective and objective scope (including foreign shareholdings and family holding companies), the new dilution mechanism in multi-tier shareholding structures, the relaxation of the single-shareholder requirement for the receiving company, and the use of contributions under the controlled realisation regime as a tool for generational succession planning, also in light of anti-abuse principles and the interaction with inheritance and gift tax rules.
The article is available on the Wolters Kluwer platform.
Read the first page HERE.
