With Order No. 24249, filed on 30 July 2026, the Italian Supreme Court (Corte di Cassazione) addressed the issue of the deductibility of interest expenses within the Italian national tax consolidation regime, establishing a significant principle for corporate groups. The case concerned a consolidated company that had deducted interest expenses accrued on intragroup receivables, which were subsequently challenged by the Italian Revenue Agency. According to the tax authorities,

With the corrective Omnibus Legislative Decree, currently under review by Parliament, the legislator is once again intervening on the rules governing contributions of shareholdings that generate a capital loss, as regulated by Articles 175, paragraph 1-bis, and 177, paragraph 2, of the Italian Income Tax Code (TUIR). The aim is to resolve an interpretative uncertainty that arose following the 2024 reform, concerning the tax value to be attributed to the shareholding received

The draft corrective legislative decree known as the “Omnibus” decree, part of Italy’s tax reform, is continuing its parliamentary process. Preliminarily approved by the Council of Ministers on 10 June 2026, it consists of 27 articles addressing personal income tax (IRPEF), corporate income tax (IRES), VAT, inheritance tax and excise duties, and was submitted to Parliament on 21 July. The text is now being examined by the Finance Committees, which must issue an opinion before

The deadline for deciding whether to opt into the new Biennial Tax Settlement scheme (Concordato Preventivo Biennale, CPB) is approaching. For the 2026–2027 period, the deadline is set for 31 October 2026; since this falls on a Saturday, it is postponed to 2 November. The settlement allows VAT-registered taxpayers subject to the ISA tax reliability indicators to agree in advance with the Italian Revenue Agency on their taxable income for a two-year period. Once the proposal h

With Ruling No. 134/2026, the Italian Revenue Agency clarified a recurring issue for Third Sector Entities (ETS) that own real estate: what happens if a property purchased under the tax relief provided by Article 82(4) of the Third Sector Code is transferred before five years have elapsed from the date of purchase? The provision allows registration, mortgage and cadastral taxes to be applied at a fixed amount of €200 each, provided that, at the time of the transaction, the en

The tax credit supporting road transport companies affected by rising diesel prices, introduced by Article 3 of Decree-Law No. 33 of 18 March 2026, converted into Law No. 79/2026, has undergone three legislative changes in just a few months. These changes have not yet been fully incorporated into the implementing decree. Initially reserved for road freight transport companies under Article 24-ter, paragraph 2, point (a), of Legislative Decree No. 504/1995, the range of eligib

By judgment no. 153/2026, filed on 24 July, the Constitutional Court redefined the scope of IRAP for professionals working within an associated professional practice. The issue concerns Article 1(8) of Law no. 234/2021, which, as of 2022, exempts individuals carrying on artistic or professional activities from IRAP. Since the provision entered into force, the Italian Revenue Agency has excluded professional associations from this exemption, as stated in Circular no. 4/E/2022,

With the arrival of August, the summer suspension periods provided by law for various tax and judicial obligations come into effect once again. However, not all deadlines follow the same timetable: depending on the type of act, the suspension periods may differ by several weeks. Starting with tax litigation, procedural time limits—such as the 60-day period for filing an appeal or lodging a petition—are suspended from 1 to 31 August (Article 1 of Law No. 742/1969). Where a tim

Among the less high-profile but more practical measures contained in the Omnibus Decree—the fourth corrective decree implementing the tax reform enabling legislation, currently under consideration by the Chamber of Deputies—Article 18 stands out. It applies to all non-resident entities carrying on business activities in Italy through a permanent establishment (PE/branch), regardless of their size or business sector. Compared with an Italian-law subsidiary, the branch remains

Anyone who sells a property and realizes a capital gain may face an unexpected tax bill. Article 67, paragraph 1, letter b) of the Italian Income Tax Code (TUIR) taxes as “miscellaneous income” any capital gain arising from the sale of properties purchased or built less than 5 years earlier; after this period, the capital gain is not taxable. Properties acquired by inheritance and those used as the seller’s or their family members’ main residence for most of the ownership per

Naples, 14 May 2026 – M&L Consulting Group took part in the 71st edition of the Premio Industria Felix – L'Italia che compete, held at Città della Scienza and co-organised with the Campania Region. The event recognised 86 Campania-based companies that have distinguished themselves for competitiveness and reliability. During the event, Ms Veronica La Gattuta, representing M&L Consulting Group, shared key insights on M&A and generational transition. In her first speech, Ms La G

Rome, April 28, 2026 – M&L Consulting Group, participated in the 70th edition of the Industria Felix Award – Italy That Competes, held at Palazzo Brancaccio in Rome. The event celebrated 79 of the most competitive companies in Central Italy and the Islands, distinguished by their financial solidity and management performance, with a positive impact on the economic growth of the territory. ​During the event, Dr. Valerio Locatelli, Co-founder and Partner of M&L Consulting Group

Corporate welfare consists of “ all benefits, projects and services provided to employees in kind or in the form of expense reimbursements, aimed at purposes that can be broadly defined as socially relevant, and excluded from employment income ” (see Circolare 28/2016 Agenzia delle Entrate). In other words, it includes a broad and heterogeneous range of initiatives set up by the employer, mainly related to work–life balance, employee care, and the provision of goods and servi

Turin, April 9, 2026 - The 69th Industria Felix Award – Italy that Competes took place at the Union of Industries of Turin, an event aimed at recognizing 42 companies from Northern Italy, selected through an algorithm that evaluates performance, financial reliability, and management skills. Representing M&L Consulting Group among the distinguished participants, Dr. Giancarlo Marengo , senior consultant at M&L Consulting Group and Studio Locatelli & Associati , played a pro

The EU Inc. proposal, presented by the European Commission on March 18, 2026, introduces a new harmonized legal framework for the establishment and management of businesses within the European Union. Its primary objective is to simplify the European business system, reduce regulatory fragmentation, and enhance the competitiveness of businesses. 1. Target audience EU Inc. will be an additional corporate form alongside the standard corporate forms under Italian commercial l

1.What are reversible compensations Reversible compensations are payments due to an employee or coordinated and continuous collaborator of a controlling company, appointed as a member of the administrative body of a controlled company, with the obligation to transfer the compensation back to the controlling company. This regulation does not apply if the administrator receives the compensation as self-employment income. Additionally, this regulation is applicable when the ad

Milan, March 19th, 2026 – The 68th Industria Felix Award – L'Italia che compete took place at Palazzo Lombardia, an event that celebrated the 70 most competitive companies in Lombardy, a prestigious recognition for the regional business landscape. Among the distinguished participants, a prominent role was played by Dr. Valerio Locatelli , Managing Partner of Studio Locatelli & Associati-Dottori Commercialisti and Partner & Co-Founder of M&L Consulting Group , with his in-

Studio Locatelli & Associati and M&L Consulting Group Leading at the 6th Edition of the Premio Industria Felix

Studio Locatelli & Associati with M&L Consulting Group's participation in the upcoming event organised by Industria Felix, on 11 December 2025 at Palazzo Mezzanotte in Milan

If you're considering transferring your fiscal residence to Italy, the Article 24-bis regime offers significant benefits