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Article 5 of Legislative Decree No. 209 of 27 December 2023, implementing the international tax reform, profoundly redefines the impatriate regime set out in Article 16 of Legislative Decree No. 147 of 14 September 2015, providing for its repeal

January 12, 2024

According to the literal wording of the rule, “The provisions of this Article shall apply in favour of persons who transfer their tax residence to Italy starting from the 2024 tax period […]” and, similarly, the previous regime is still applicable “[…] in favour of persons who have transferred their registered residence to Italy by 31 December 2023 […]”.

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Studio Tributario Deiure with Wellness Holding in the investment in Acqua Filette S.r.l.

Studio Tributario Deiure assisted Wellness Holding, the single-family office of Nerio Alessandri, founder of Technogym, and a group of investors in the acquisition of a minority stake in Acqua Filette S.r.l., a company engaged in the production of ultra-premium mineral water in the luxury segment.

Sustainability reporting – Directive (EU) 2025/794

On 14 April 2025, Directive (EU) 2025/794 of the European Parliament and of the Council was published in the Official Journal of the European Union. This directive amends Directives (EU) 2022/2464 and (EU) 2024/1760 concerning corporate sustainability reporting and corporate due diligence for sustainability purposes. This measure is part of the regulatory simplification package promoted by the European Commission, aimed at reducing the administrative burdens on businesses.

Studio Tributario Deiure with Vergani in the acquisition of Pasticceria Scarpato

Studio Tributario Deiure assisted Vergani, a historic confectionery company that has been producing panettone cakes for over 80 years, in the process of acquiring Pasticceria Scarpato, a company active since 1888 in Villa Bartolomea (VR).

Premial IRES – Measures for approving the 2024 budget

The 2025 Budget Law (L. 207/2024) introduced, applicable only to the tax period following the one in progress on 31.12.2024, a significant tax incentive: the application of a reduced IRES rate of 20% (as opposed to 24%) for corporations that meet specific requirements.

Taxation of Long-Term Cash Bonuses under International Mobility: Clarifications from the Italian Tax Agency

With Ruling No. 81/2025, the Italian Tax Authorities have addressed a case of international taxation regarding the payment of a Long-Term Cash Bonus to an employee who had returned to Italy. The Authorities clarified that taxation must occur in the country where the work activity was effectively carried out during the vesting period, regardless of the beneficiary's tax residence at the time of payment.

The 2025 Reform on the Revaluation of Tax Expenditure regarding Land and Equity Holding

2025 Budget Law (Law no. 207/2024) Paragraph 30 lays out the official framework for the revaluation of tax expenditure regarding equity holding (both listed and unlisted) and land (agricultural and developable), consolidating a provision that has been subject to numerous extensions in the past.

PERSONNEL SECONDMENT – Important information for VAT purposes

Law 166/2024 was published in the Official Journal under number 267 of 14 November 2024, converting Legislative Decree 131/2024 (the so-called EU Infringement Rescue Decree), and contains provisions for the closure of a series of infringement procedures with the European Union, including one concerning the VAT regime for the secondment of personnel.

New tax residency regulations – Ministerial Memorandum no. 20

The Italian Tax Revenue Agency, with the publication of ministerial memorandum no. 20/E of 4 November, reveals the effects of the changes introduced by Legislative Decree 209 of 2023 (Implementation of tax reform in international taxation) regarding the tax residence of individuals, companies and entities that have been operational starting from 2024.

Clarifications regarding share transfers and mergers – Tax Revenue Agency Answer no. 200/2024

The Italian Tax Revenue Agency, in response to question no. 200 of 11 October 2024, considered a series of extraordinary transactions consisting of two induced neutrality transfers (pursuant to art. 177 co. 2 and 2-bis of the TUIR, Italy’s Consolidated Law on Income Tax) and a merger to be evasive.

New PVC – Digital Signature for Subscription

On 30 September 2024, pursuant to article 38-bis, paragraph 2 of Presidential Decree 600/73, provision no. 372380 of the Tax Revenue Agency was published, clarifying the procedures for signing tax audit reports issued at the conclusion of administrative tax control activities by the members of the Tax Revenue Agency.
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Studio Tributario Deiure with Wellness Holding in the investment in Acqua Filette S.r.l.

Sustainability reporting – Directive (EU) 2025/794

Studio Tributario Deiure with Vergani in the acquisition of Pasticceria Scarpato

Premial IRES – Measures for approving the 2024 budget

Taxation of Long-Term Cash Bonuses under International Mobility: Clarifications from the Italian Tax Agency

The 2025 Reform on the Revaluation of Tax Expenditure regarding Land and Equity Holding