Controlled Realization Regime: New Qualification Requirements for Equity Investments and Holding Company Contributions in the IRPEF and IRES Reform Legislative Decree Implementing Law 111/2023

7 Controlled Realization Regime: New Qualification Requirements for Equity Investments and Holding Company Contributions in the IRPEF and IRES Reform Legislative Decree Implementing Law 111/2023 The recent draft decree implementing Articles 5, 6 and 9 of the enabling act for tax reform (Law 111/2023) introduces significant changes to the regime for equity contribution transactions, with…