Marzo 15, 2020
International mergers and Italian anti-abuse regulations
The Italian Tax Authorities have recently published some interesting responses in tax rulings concerning the international reorganization operations.
In one of these, the situation of a group with a parent company and a sub-holding company both resident in France and three operating companies resident in Italy was examined.
The operation analyzed consisted of the merger in France of the sub-holding company into the parent company, following which the parent company became the direct owner of the shareholdings in the three Italian operating companies.
(altro…)