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The demerger by demerger split as a worthwhile alternative to the transformation of a permanent business establishment in Italy into a subsidiary

As already discussed in a previous article (ed. March 5, 2024), with the introduction of Article 2506.1 into the Civil Code, a new form of partial corporate split-up known as demerger by demerger split has been included in our legal system, through which the demerged company assigns part of its assets to one or more newly established companies (or even for the benefit of pre-existing companies, as provided by Bill No. 209 of November 7, 2023 of the Milan Notary Council) receiving in exchange shares or quotas of said company.

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We are proud to announce that our firm has received the "Tax: Dispute Resolution" award from TopLegal for its outstanding assistance in tax audits relating to transfer pricing and permanent establishments of multinational groups, settling disputes and obtaining significant reductions in tax claims.
A long-awaited clarification: with Resolution No. 7 of 12 February 2026, the Italian Revenue Agency has finally intervened on the VAT treatment of transaction costs in the context of an MLBO (merger leveraged buy-out) transaction carried out pursuant to Article 2501-bis of the Italian Civil Code.
Studio Tributario Deiure assisted the founding family of SAIM Impianti and SAIM Service in the sale of these companies to Frigoveneta, a platform company of Ambienta SGR, a European asset manager active in investments focused on environmental sustainability.
The 2026 Budget Law (Law No. 199 of 30.12.2025 - Official Journal no. 301 of 30.12.2025) includes a wide range of tax measures.
Studio Tributario Deiure assisted ITAGO SGR S.p.A. in the sale of Panificio San Francesco S.p.A., a company active in the production of pre-baked and frozen bread for large-scale distribution, to Lantmännen Unibake, an international bakery group and one of the leading European operators in the sector, owned by the Swedish agricultural cooperative Lantmännen.
Along with Studio Tributario Deiure, the Med'Or Foundation took part in the Italy-Saudi Arabia Business Forum. We extend a special thanks to the Foundation and Dr. Massimo Khairallah for their ongoing dedication and support for our firm.
Our firm had the honor of participating in the Italy-Saudi Arabia Business Forum, an event organized by the Ministry of Foreign Affairs and International Cooperation as well as the Italian Trade Agency, which took place in Riyadh on 25 and 26 November.
The international journey of Studio Tributario Deiure continues to draw new paths for dialogue and collaboration.
November marked an important opportunity for Studio Tributario Deiure to strengthen its international relations in the United Arab Emirates through a series of institutional meetings, including visits to Dubai’s major Free Zones.
Studio Tributario Deiure assisted B&B Trends Group in the acquisition of a business unit from Poly Pool S.p.A., a Bergamo-based company operating in the electrical materials sector.

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