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Mid-year tax decree: new rules on payments, CFC and VAT

June 18, 2025

With its publication in the Official Journal on 17.06.2025, the decree law approved by the Council of Ministers on 12.06.2025 (no. 84/2025 – the “Decree” or “DL”) comes into effect. The Decree addresses various aspects of tax legislation, introducing amendments designed to simplify, correct, and coordinate recent changes introduced in recent months.

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Extraordinary Operations – Tax updates from Legislative Decree 84/2025

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.

Roundtable – United Arab Emirates: business opportunities for italian companies

Studio Tributario Deiure with Decorluxe Group in the investment in Issco S.r.l.

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.

Tax Credit 4.0: one week left before the deadline for submitting notification of ‘unreserved’ investments

Following the Ministerial Decree of 15 May 2025 and subsequent implementational decree of 16 June, the MIMIT (Ministry for Business and Made in Italy) has redefined the procedures granting access to the 4.0 tax credit relating to investments made in 2025 (or by June 2026, with a 20% partial payment by 31 December 2025). The new procedure entails the submission of three separate communications via the GSE platform: (1) preliminary communication (2) communication with partial payment (within 30 days of (1)) and finally (3) communication of completion.

Mid-year tax decree: new rules on payments, CFC and VAT

With its publication in the Official Journal on 17.06.2025, the decree law approved by the Council of Ministers on 12.06.2025 (no. 84/2025 – the “Decree” or “DL”) comes into effect. The Decree addresses various aspects of tax legislation, introducing amendments designed to simplify, correct, and coordinate recent changes introduced in recent months.

Accreditation by Dubai Chambers for the development of Italian businesses in the GCC

Studio Tributario Deiure has been accredited by Dubai Chambers, Dubai Chamber of Commerce, a key driver of economic development and international business growth in Dubai. Dubai Chambers is an institutional body that maintains an ongoing dialogue with the highest authorities of the United Arab Emirates, playing a strategic role in strengthening the global competitiveness of the Emirate.

Italian Revenue Agency Ruling no. 131/2025: Clarifications on the nominal tax rate test applicable to foreign dividends

With ruling no. 131/2025, the Italian Revenue Agency clarified that, for the purposes of Article 47-bis, paragraph 1, letter b) of the TUIR (Italian consolidated law on income tax), the test of the nominal level of taxation – used to determine whether a foreign tax regime qualifies as preferential in cases of non-controlling shareholdings – must be carried out based solely on the IRES rate (24%), without taking into account either IRAP or withholding taxes applied to dividends payable.

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).
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articoli recenti

Extraordinary Operations – Tax updates from Legislative Decree 84/2025

Roundtable – United Arab Emirates: business opportunities for italian companies

Studio Tributario Deiure with Decorluxe Group in the investment in Issco S.r.l.

Tax Credit 4.0: one week left before the deadline for submitting notification of ‘unreserved’ investments

Mid-year tax decree: new rules on payments, CFC and VAT

Accreditation by Dubai Chambers for the development of Italian businesses in the GCC