Circulars 9/2011 - Mid-August maneuver 1

Mid-August maneuver 1

Shell companies and cooperatives

Law Decree no.138 of 13 August 2011 (hereinafter "Maneuver of Ferragosto" or "Maneuver"), converted into Law no.148 of 14 September 2011, introduced new measures against the financial crisis, aimed at promoting the stabilization of public accounts in the two-year period 2012 - 2013. The purpose of this circular is to provide initial information on the main changes that have taken place in the matter of shell companies and cooperatives.

With the subsequent circulars, the numerous other issues opened by the Maneuver regarding:

1. tax treatment of assets used by shareholders
2. corporate criminal liability
3. taxation of financial income
4. residual interventions

Topics index

1. Shell company
   1. subjective scope
   2. objective scope
   3. increase in the IRES rate
   4. repeated loss for three years
   5. consequences of non-operation for IRAP and VAT purposes
2. Cooperative Societies
   1. increase in the percentage of taxation of net profits
   2. taxation of profits earmarked for minimum compulsory reserve
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