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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.

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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.
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.
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.
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.
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 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.

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