
Il Fisco stringe le maglie sui conferimenti d’azienda
Publication date
06/2025
Language
Italian
Article by Angelo Rocco Bonissoni and Luca Vitale
Decree-Law No. 84/2025 introduces significant changes to the tax regime applicable to business transfers or contributions, extending certain limitations already in place for other extraordinary transactions concerning the carry-forward of tax losses and interest expenses.
The new rules apply to transactions carried out starting from the tax period underway as of 31 December 2024. However, it remains to be clarified whether any retroactive application of these restrictions may conflict with the principle of non-retroactivity in tax law.
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Il Fisco stringe le maglie sui conferimenti d’azienda | 2.01 MB |
Angelo Rocco Bonissoni
Luca Vitale