This document comments on the Italian Revenue Agency's Ruling no. 271 of October 27, 2025, which applies for the first time the tax reform's revised provision (Art. 3, paragraph 4-ter of Legislative Decree no. 346/1990) concerning generational transfers. The key takeaway is that the exemption from donation tax for the transfer of company shares to descendants also applies to holding companies. This ruling confirms that the requirement to continue the business activity applies only to transfers of companies or business branches, not to transfers of shares or quotas.
Passaggi generazionali: ambito applicativo dell’esenzione dopo la riforma fiscale
annalisa pace
2025-01-01
Abstract
This document comments on the Italian Revenue Agency's Ruling no. 271 of October 27, 2025, which applies for the first time the tax reform's revised provision (Art. 3, paragraph 4-ter of Legislative Decree no. 346/1990) concerning generational transfers. The key takeaway is that the exemption from donation tax for the transfer of company shares to descendants also applies to holding companies. This ruling confirms that the requirement to continue the business activity applies only to transfers of companies or business branches, not to transfers of shares or quotas.File in questo prodotto:
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