In the May 2025 Newsletter of the CEIPIEMONTE s.c.p.a. Francesco Scarfone outlines the main amendments to the rules on contributions of shareholdings made by Article 17 of Legislative Decree No. 192 of 13 December 2024, which makes explicit the applicability of the regime of “controlled realization” referred to in Article 177, Paragraphs 2 and 2-bis, Italian Income Tax Code, even in the case in which the “exchanged” company is not resident for tax purposes in Italy.
The new rules apply to contributions of shareholdings made as from 31 December 2024: https://lnkd.in/dYvcv2mY