TAX PILLS

The IMU exemption may also apply where a non-commercial entity grants a property free of charge to another non-profit entity for the purpose of carrying out qualifying activities on a non-commercial basis. This principle was affirmed by the Lazio Regional Tax Court of Second Instance in Judgment No. 1724/2026, concerning a property granted on loan

A mortgage lien may be registered over assets contributed to a family asset fund (fondo patrimoniale) even where the underlying tax liability arises from the business or professional activities of either spouse. The Italian Supreme Court reaffirmed this principle in Judgment No. 25114 of 8 September 2026, clarifying that the business origin of a debt

Income attributed to an Italian-resident beneficiary of a transparent foreign trust must be determined in accordance with the tax rules of the jurisdiction in which the trust is resident or established. This was clarified by the Italian Tax Authority in Ruling No. 165/2026, concerning a trust established in the United States that became transparent following

In chain transactions, the mere physical removal of goods from the Member State of departure is not, in itself, sufficient to ensure that the first supply qualifies for VAT exemption. In its judgment of 9 September 2026 in Case T-614/25, the General Court of the European Union examined a triangular transaction in which goods were

The transfer of a business, free of charge and in equal shares to two beneficiaries, does not necessarily qualify as a transfer of a totality of assets falling outside the scope of VAT. In its judgment of 9 September 2026, Case T-366/25, the General Court of the European Union examined a transaction whereby an entrepreneur intended to transfer his entire

A share capital increase paid up by setting off receivables owed to shareholders is subject to registration tax at a rate of 0.5%, rather than merely to the fixed registration tax of EUR 200. This principle was established by the Italian Supreme Court in Order No. 25106/2026. The case concerned a company which, after reducing

The deadline for paying the first – or sole – instalment under the Rottamazione-quinquiestax settlement scheme is 31 July 2026. Please note that the five-day grace period does not apply to the first instalment where payment by instalments has been selected. The applicable rules differdepending on the payment option chosen: lump-sum payment. The payment will