The Italian Accounting Standards Board (Organismo Italiano di Contabilità – OIC) has recently published the final version of the new OIC 5 “Liquidation Financial Statements”, which entirely replaces the previous version of the standard and redesigns its valuation criteria and the financial statement formats required by art. 2490 of the Italian Civil Code. The new text applies to liquidation financial statements for financial years beginning on or after 1 January 2027, with th

The deadline to join the Biennial Preventive Tax Agreement (concordato preventivo biennale, CPB) for 2026-2027 expires on 2 November and, just a few weeks before that date, the Italian Revenue Agency has published Circular No. 8/E of 6 October 2026. The document runs to around eighty pages and, as stated in its introduction, replaces the previous circulars and systematically reorganises the entire regime, taking into account the amendments introduced by Legislative Decree No.

Holding companies appear to be the most common way in which groups are organised, even small ones: a company that neither sells nor produces anything, but simply holds the shares in the operating companies, perhaps providing them with some services. When such a company disposes of a shareholding, the question that arises is only apparently simple: is that consideration subject to VAT, or does it fall entirely outside its scope? The answer is not a technical detail, because it

Article 16-bis(3) of the Italian Income Tax Code (TUIR) grants the purchaser of a property unit located in an entirely renovated building a tax deduction currently equal to 36% (50% in the case of a main residence) of 25% of the purchase price stated in the deed, up to a limit of EUR 96,000. Among other conditions, the provision requires the works to have been carried out by construction or building renovation companies, or by housing cooperatives. However, since the notion o

1. The End of the Emergency Regime From 1 October 2026, shareholders' meetings and other collegial meetings can no longer be held remotely on the basis of the emergency legislation. Article 106(7) of Decree-Law No. 18/2020 (the so-called "Cura Italia" Decree) allowed corporations to hold meetings virtually by means of telecommunication, without having to designate a physical meeting place, even in derogation from the articles of association. Originally conceived as a temporar

1. Overview of the reform Legislative Decree No. 47 of 27 March 2026, in force since 29 April 2026, has reworded the provisions of the Italian Civil Code governing the management and control of joint-stock companies (S.p.A.). The main structural change concerns Art. 2380 of the Civil Code. Until 28 April 2026, unless the articles of association provided otherwise, the traditional system (directors and board of statutory auditors) applied. The new wording no longer sets a defa

1. The rules in brief Corporate welfare comprises the benefits, works and services that the employer grants to all employees or to categories of employees, in kind or by way of expense reimbursement, for purposes of social relevance. The legal basis is art. 51, para. 2, of the TUIR (Italian Income Tax Code), which provides that they do not form part of employment income. The most relevant cases are: letter f): works and services offered to all employees or to categories of em

Work on the next Budget Law is under way, but for now the scope of the tax measures rests on early comments made in interviews and public speeches. None of the proposals is contained in a legislative text: the Draft Budgetary Plan (Documento Programmatico di Bilancio) has yet to be submitted to Parliament. The indications gathered in recent days should therefore be read for what they are: statements of intent, often conditional and hypothetical. Irpef: the 33% rate up to EUR

During the "Speciale Telefisco" event held on 24 September, the Italian Revenue Agency (Agenzia delle Entrate) clarified that the option for upfront taxation of trusts may be exercised even where the application of the tax-free allowances exhausts the entire taxable base, so that no tax is actually payable. The general rule and the derogating option As a general rule, Article 4-bis of the Consolidated Law on Inheritance and Gift Tax (TUS) identifies the taxable event for inhe

Introduction This article is the third in a series dedicated to the taxation of financial investments held by individuals. In the first part we introduced the fundamental distinction between investment income and miscellaneous financial income, together with the summary framework of the tax rates applicable to the main financial instruments; in the second part we analysed the three tax regimes - declarative, administered and managed - together with their respective advantages

Introduction Understanding how your financial investments are taxed is essential for the informed management of your wealth. In Italy, the tax treatment for individuals varies significantly depending on the type of financial instrument, the nature of the income produced, and the tax regime chosen. Knowing these rules makes it possible to optimise your portfolio, avoid surprises when filing your tax return, and make the most of the opportunities for offsetting gains and losses

Introduction This article is the second in a series dedicated to the taxation of financial investments held by individuals. In the first part, we introduced the fundamental distinction between investment income and miscellaneous financial income, as well as the summary framework of the tax rates applicable to the main financial instruments. In this second contribution, we examine the three tax regimes — declarative, administered, and managed — through which individuals declar

In professional practice, cases are increasingly arising in which the Italian Revenue Agency, despite a now well-established body of case law confirming the primacy of treaty or EU law over domestic legislation, continues to deny taxpayers’ claims at the administrative stage, forcing them to initiate litigation in order to obtain recognition of their rights. This phenomenon affects international taxation of both individuals and companies and can be analysed through three rece

In recent days, the Labour Section of the Italian Supreme Court of Cassation has issued a series of closely spaced rulings with substantially consistent reasoning. By rejecting the appeals filed by INPS, the Court held that profits retained as reserves by an S.r.l. (Italian limited liability company) not subject to the tax transparency regime do not contribute to the formation of the social security contribution base for IVS purposes (Invalidity, Old Age and Survivors insuran

The rules governing tax loss carryforwards have undergone a significant revision, aimed at ensuring greater consistency in the provisions applicable to changes in control and extraordinary transactions, while preserving their anti-abuse purpose of preventing tax loss trafficking. Basic rules As a general rule, Article 84 of the Italian Tax Code (TUIR) allows tax losses to be carried forward without any time limitation, with the possibility of offsetting them against up to 80%

A family business may be transferred to children and/or the spouse without triggering inheritance or gift tax. However, Article 3(4-ter) of the Italian Consolidated Inheritance and Gift Tax Act (Legislative Decree No. 346/1990) requires the successors, for a period of five years, to alternatively: continue the business activity, where a business as such is transferred; maintain control pursuant to Article 2359 of the Italian Civil Code, where shares in capital companies are t

During 2026, the framework of contribution incentives for hiring has been expanded with several measures, each distinguished by purpose, requirements, and duration: such a large number of bonuses has understandably created some uncertainty among companies as to which measure applies to which type of hiring. This is demonstrated by the issue of the 30 September 2026 deadline, which has been widely reported in recent weeks by many sources and sometimes incorrectly presented as

On 6 July 2026, the Italian Revenue Agency and the Italian Accounting Standards Board (OIC) published a joint technical note dedicated to cryptocurrencies held by companies: a guidance document that, for the first time, provides an organised and coordinated overview of their accounting and tax treatment. More and more companies are holding Bitcoin, Ethereum or other cryptocurrencies, but Italian accounting standards have never provided specific rules for these assets. The new

Among the changes introduced by the new Consolidated Income Tax Act (Legislative Decree No. 117 of 12 August 2026) is a reform set to affect the finances of a very broad group of workers: the repeal of the so-called “safeguard clause” on the taxation of severance pay (TFR), which was introduced in 2006 and has remained in force ever since. The legislative change and its impact Article 376 of Legislative Decree No. 117/2026 repeals Article 1, paragraph 9, of Law No. 296/2006,

Among the measures addressed by the Omnibus Decree (Legislative Decree No. 148 of 7 August 2026, in force from 12 August 2026) is also an issue that, since its legislative introduction in 2024, has given rise to significant interpretative and practical uncertainties: the exercise of the option for the “upfront taxation” of trusts. The legal basis of Article 4-bis of the TUS The reform of inheritance and gift taxation (Legislative Decree No. 139/2024) introduced the new Articl