The Italian Revenue Agency, in its ruling no. 160/2024, analyzed the potential abusive aspects of a company reorganization based on two contributions of shares under two different tax regime, pursuant to Article 177, paragraphs 2 and 2-bis of the Italian Income Tax Code (TUIR), both suitable, under certain conditions, to guarantee the neutrality of the transaction.
Belluzzo International Partners has been recognised as a Firm Leader in the Private Client category by the ITR World Tax Guide 2025, with excellent rankings in Transactional Tax, Tax Controversy, Transfer Pricing and General Corporate Tax.
The Italian Supreme Court, in its ruling no. 22608 of August 9, 2024, established the right to VAT deduction for a Special Purpose Vehicle (SPV) involved in a merger leveraged buyout (MLBO) operation.
Luigi Belluzzo in un articolo pubblicato su Il Sole 24 Ore dell’8 agosto 2024 commenta la modifica del comma 2 dell’art. 24bis Tuir (Nuovi Residenti Fiscali) introdotta dal Dl Omnibus
The Meloni Government, with the “Omnibus” Decree, has planned to amend paragraph 2 of Article 24-bis of the TUIR (New Tax Residents) by doubling the optional substitute personal income tax due by new tax residents on all foreign income.
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