Ruling 6th April 2022, No. 165: Ephemeral Tax Consolidation

In the recent Ruling 6th April 2022, No. 165 the Italian Revenue Agency has excluded the existence of abusive profiles  in the case of election for the Tax Group Regime where the same is exercised ab origine with the “knowledge” of the possible interruption in a short period of time due, for instance, to the circumstance of liquidation of the consolidated companies. According to the Tax Administration, even if it is exercised in such or similar circumstances of “imminent” causes of interruption, the option does not entail the achievement of any “undue” tax advantage, i.e. in contrast with the purposes of the rules governing the Tax Group Regime.

Full text of the Ruling here.