Category Archives: news

Tax Transparency for Multinationals: New Obligations According to Legislative Decree 128/2024 and Directive 2021/2101/EU

The Legislative Decree No. 128/2024 , implementing European Directive 2021/2101/EU, imposes important tax transparency obligations on multinational companies with consolidated revenues exceeding 750 million euros. This decree aims to increase tax transparency and accountability by requiring large companies to publish detailed information on income taxes accrued and paid in the countries where they operate. Reporting…

VAT in MLBO Transactions: Deduction and Cost Recovery for Vehicle Companies.

VAT in MLBO Transactions: Deduction and Cost Recovery for Vehicle Companies. Merger leveraged buyouts (MLBOs) are a complex financial process in which a special purpose vehicle (SPV) temporarily acquires a “target” company and then merges with it, establishing control. This structure makes the SPV a taxable person for VAT purposes, and thus makes it eligible…

Taxation | Direct Taxes | General Provisions | Deductible Charges | Superbonus

Changes to the Controlled Realization Regime Notice of Options for Credit Transfer or Invoice Discount – Cancellation – Impugnability – Litigation between Deduction Recipient and Contractor who Performed the Work Current Italian tax legislation, particularly with reference to the Superbonus, includes specific provisions regarding the disclosure of options for credit assignment or invoice discounting. In…

Financial Statements: Valuation Criteria for Tangible Assets and Depreciation

Financial Statements: Valuation Criteria for Tangible Assets and Depreciation Suspension of Depreciation – Allocation of Profits to Reserve – Method of Release of Reserve The management of tangible and intangible assets represents a crucial aspect in the preparation of the annual financial statements. The suspension of depreciation, provided for in Art. 60 co. 7-ter of…

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…

Tax Advantages in Creating a Holding Company: A Strategic Approach for Corporations

Establishing a holding company is a significant strategic move for many companies, both domestically and internationally. This approach offers a number of tax advantages that can optimize financial management and improve the operational efficiency of the entire group. Below, we will explore the main tax benefits associated with establishing a holding company. 1. Optimization of…

The New Legal Interest Rate and Its Tax and Taxpayer Repercussions: A Complete Guide

The New Legal Interest Rate and Its Tax and Taxpayer Repercussions: A Complete Guide   As part of the constant regulatory and fiscal developments affecting the Italian landscape, one of the most relevant changes for the year 2024 concerns the reduction of the legal interest rate. With the Ministerial Decree of November 29, 2023, published…

The OECD and the evolution of international taxation.

The OECD and the evolution of international taxation.       The Organization for Economic Cooperation and Development (OECD) is addressing international tax challenges with a two-pillar approach, as agreed by the Inclusive Framework (IC) of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project in 2021. The BEPS Project has made significant progress in…