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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.

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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.
Legislative Decree 84/2025 introduces significant provisions concerning the transfer of losses in extraordinary operations, setting out important changes to the limitations on tax loss carryforwards.
Studio Tributario Deiure assisted Decorluxe Group in the acquisition of 100% of Issco S.r.l., a company active in surface finishing for packaging in the perfumery, cosmetics, and wine&spirits sectors.

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