Recapitalisations with waiver of credits and registration tax
It should be noted that, with sentence no.15585 of 30 June 2010, the Supreme Court sanctioned the obligation to subject the loan agreement between the shareholders and the company to a proportional registration tax, if mention is made of it. in the minutes of the extraordinary meeting to cover losses, due to the waiver of the related credit.
This circular analyzes the conditions for the onset of this obligation and what solutions can be used to allow the taxability to be overcome.
Topics index
- The analysis of the case for the purposes of registration tax
- Brief note of the reasons
- The waiver is tax exempt
- Possible solutions