Tax News and Insights
Legislative updates, case law analysis and insights from our team of experts.
54 articles found · Page 2 of 6
Trusts and property purchases: when the price-value method applies (Treviso Tax Court no. 288/2025)
In judgment no. 288 of 12 August 2025, the Treviso Tax Court recognises an individual trustee's entitlement to use the price-value method for purchases of residential property intended for the trust fund, contrary to the guidance of the Italian Revenue Agency (Agenzia delle Entrate).
Cross-border workers, a distinction in the regime: Bank of Italy employees in France are taxed only in Italy
Italian Revenue Agency (Agenzia delle Entrate) tax ruling (risposta a interpello) no. 132/2026 excludes Bank of Italy employees resident in France from the cross-border workers regime: Article 19 of the Italy–France Convention applies, with exclusive taxation in Italy.
Non-deductible pro-rata VAT and IRAP: accruals, not cash
Non-deductible pro-rata VAT: for IRAP purposes, the accruals basis under civil law applies, not the cash basis under art. 99 of the Italian Income Tax Code (TUIR). Ravenna Tax Court judgment no. 227/2026 and its practical implications.
Price-value and trusts: why an individual trustee can (and should) use it
Price-value and trusts: where the trustee is an individual, the option is available. Treviso Tax Court (Corte di Giustizia Tributaria) 288/2025, Italian Supreme Court (Corte di Cassazione) 3073/2021 and Bologna Tax Court (Corte di Giustizia Tributaria) 75/2025 against Circular 34/E/2022.
Is a debt discharge order subject to proportional or fixed tax?
Debt discharge orders and registration tax: the Italian Supreme Court (Corte di Cassazione) (17174/2026) opts for the fixed amount. Legal effects prevail, not economic effects.
Trust beneficiary and removal of s.r.l. directors (Court of Rome, 16 January 2026)
A trust beneficiary has no standing to seek the interim removal of s.r.l. directors: the order of the Court (Tribunale) of Rome of 16 January 2026.
Seasonal workers: standard IRES calculations
Preferential corporate income tax (IRES) and seasonal workers: the ordinary rules also apply to the employment requirement, according to MEF. Risks and unresolved issues.
Second Insolvency Directive: Access to Trusts Without Prior Notice
EU Directive 2026/799 transforms asset tracing: bankruptcy trustees (curatori) will have direct, "silent" access to the Register of Beneficial Owners of trusts and fiduciary mandates.
Marzo Associati at the Luiss Guido Carli Career Day
Marzo Associati is taking part in the Luiss Guido Carli Career Day, seeking young talent in tax and corporate law and investing in the future and in an agile environment.
All Insights Articles
- Compliance letters on 2023 revenue: how to respond to the Italian Revenue Agency (Agenzia delle Entrate)
- Trusts and creditors: when a property may be sold at auction
- Dividends, Charitable Trusts and Foundations: the Shift by the Italian Supreme Court (Corte di Cassazione)
- Commercial irrationality: not enough on its own
- Freedom in Generational Transfers
- Black list: the calculations need revisiting
- Transfers of immovable property into trust and discharge from debts: the limits of the assessment of deservingness (Florence Court of Appeal, 17 December 2025)
- Superbonus in its final season: updated form now available for the remaining categories
- Corporate income tax (IRES) credit, a prescribed route: a refund claim cannot be converted into an intra-group transfer
- Trusts and property purchases: when the price-value method applies (Treviso Tax Court no. 288/2025)
- Cross-border workers, a distinction in the regime: Bank of Italy employees in France are taxed only in Italy
- Non-deductible pro-rata VAT and IRAP: accruals, not cash
- Price-value and trusts: why an individual trustee can (and should) use it
- Is a debt discharge order subject to proportional or fixed tax?
- Trust beneficiary and removal of s.r.l. directors (Court of Rome, 16 January 2026)
- Seasonal workers: standard IRES calculations
- Second Insolvency Directive: Access to Trusts Without Prior Notice
- Marzo Associati at the Luiss Guido Carli Career Day
- Single Betting Tax: Italian Supreme Court (Corte di Cassazione) 2026 | Marzo Associati
- VAT Adjustments and Reverse Charge: The Italian Supreme Court Blocks Cashback Refunds
- Debt Restructuring and Tax: A Bar on Post-Approval Assessments
- How to lawfully avoid paying tax payment notices: 2026 guide
- Limitation periods for a tax payment notice (cartella): time limits, calculation and how to invoke them in 2026
- Trusts and the Italian Supreme Court (Corte di Cassazione): Acts Ineffective Without Express Clauses
- Rottamazione Quinquies 2026: eligibility, savings and deadlines
- Tax Payment Notice Instalment Plans 2026: 120 Instalments, Lapse and New Rules
- Holding Companies: Contributions and Gifts Do Not Constitute Abuse
- Bank account attachment by the Italian Tax Collection Agency: how to stop it
- Additional 2025 single SEZ tax credit: how to access it from 15 April 2026
- Administrative car immobilisation: how to have it lifted, timescales and costs in 2026
- Third-Party Statements and Synthetic Tax Assessments: Proof or Circumstantial Evidence? The Italian Supreme Court (Corte di Cassazione) in 2026
- Non-deductibility of legal costs for directors’ criminal defence: a further rejection by the Italian Supreme Court (Corte di Cassazione)
- Minor heirs: immediate obligation to file income tax returns, tax authorities do not await the inventory
- Trusts and Creditors: When Asset Protection Is Not Enough
- Bank Account Assessments and Relatives’ Accounts: The Italian Supreme Court (Corte di Cassazione) Confirms the Reversal of the Burden of Proof
- Rottamazione-quinquies: scope, effects and systemic issues
- Capital gains in business income: the end of "generalised" spreading
- Defects in Service of a Tax Payment Notice (cartella): When It Is Void
- Ex officio cancellation of collection rolls: limits on deemed consent for procedural defects
- Short-term lets and Airbnb: from 2026, three homes trigger VAT registration
- Suspending a Tax Payment Notice (cartella): 3 Legal Options in 2026
- Erroneous Tax Payment Notice: How to Challenge a Debt Not Owed
- Italian Supreme Court (Corte di Cassazione) 1667/2026: notices to shareholders, attachments are optional and the duty to state reasons can also be satisfied by reference
- Corporate interposition and closely held companies: profits go to the actual shareholders
- Tax Payment Notice (Cartella) Addressed to a Deceased Person: Must the Heirs Pay?
- Difference Between a Tax Payment Notice (cartella) and a Tax Assessment Notice
- 2026 Budget Law: Tax Changes for Businesses and Professionals
- Trusts and Generational Succession: A Practical Guide
- International Tax Planning: Opportunities and Risks
- First-home tax relief for AIRE registrants: the concept of "activity" expands to include study and volunteering
- Losses on debts in insolvency proceedings: the Italian Supreme Court (Corte di Cassazione) sets the "time window" for deductibility
- Public Gambling Reform: What Changes for Concession Holders
- Italian Supreme Court (Corte di Cassazione): Key Judgment on Transfer Pricing
- ADM: New Guidelines for Online Gaming Operators