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n. 15/2016 - Clarifications on tax consolidation

Clarifications on tax consolidation

  With the publication of Circular no. 40 / E of 29 September 2016, the Revenue Agency provided important clarifications on the subject of adherence to or continuation of the national tax consolidation regime. Starting from the regulatory framework referred to in Articles 117 and following of the TUIR, as well as by the indications of the European Court of Justice regarding freedom of establishment, the tax administration intervened: (I) acknowledging the changes made by the Legislative Decree. 147/2015 (cd "Internationalization Decree") on the subject of freedom of establishment and internationalization of companies; (Ii) providing fundamental interpretative guidelines, in response to specific requests for ruling. Here we will analyze the clarifications provided by the AGE in relation to the following issues:
  1. Equity investments in pledge;
  2. Seizure of shareholdings;
  3. Newly acquired companies;
  4. Partial demerger.
  Newsletter no. 15/2016

Newsletter 2016

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