Favourable tax ruling for the Firm on a transnational incorporation made by an Italian banking group
The team from Tremonti Romagnoli Piccardi e Associati, composed of partner Cristiano Caumont Caimi and senior associate Ilaria Cherchi, successfully assisted an Italian banking group in obtaining a ruling in an anti-abuse proceeding concerning the repatriation to Italy, via an international merger, of the group’s Luxembourg-based subsidiary.
The Italian Revenue Agency shared the view of the economic logic of the transaction, and confirmed that it does not present any abusive aspect, being fully alternative to a liquidation and not allowing any undue tax benefit to be obtained.
In support of the legitimacy of the transaction, the Agency highlighted, in particular, the absence of erosion of the tax base, the permanence of the liquidity and of the repatriated securities in the business cycle and the absence of “black list” holdings among the assets involved.
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