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The new regulation of shell companies and the desirable implications for Special Purpose Vehicles (SPVs) in connection with Judgment 3361/2022

Article 9, paragraph 1, letter b), numbers 1) and 2) of the Enabling Act for Tax Reform has provided for a substantial change to the regulation of shell companies, in order to bring the rule back to its original purpose

Application of the PEX regime to EU entities as well without a permanent establishment in Italy

Article 16 of the 2024 Budget Law, currently in drafting phase, extends the participation exemption rules also to capital gains deriving from the transfer of qualified participations

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The new regulation of shell companies and the desirable implications for Special Purpose Vehicles (SPVs) in connection with Judgment 3361/2022

Application of the PEX regime to EU entities as well without a permanent establishment in Italy