Tax News and Insights
Legislative updates, case law analysis and insights from our team of experts.
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Single Betting Tax: Italian Supreme Court (Corte di Cassazione) 2026 | Marzo Associati
Order 9347/2026 of the Italian Supreme Court (Corte di Cassazione) on Single Betting Tax defines the application of the actual-margin regime for compliant operators and the flat-rate regime for non-compliant operators, allowing detailed evidence.

VAT Adjustments and Reverse Charge: The Italian Supreme Court Blocks Cashback Refunds
The Italian Supreme Court (Corte di Cassazione) (Order 10259/2026) blocks VAT refunds on cashback where the upstream transaction is subject to the reverse charge, clarifying that downward adjustments are not available.

Debt Restructuring and Tax: A Bar on Post-Approval Assessments
Debt restructuring: court approval binds the tax authorities. The Italian Supreme Court (Corte di Cassazione) bars post-approval tax assessments for pre-existing claims, except where previously unknown "new elements" emerge, strengthening safeguards for taxpayers.

How to lawfully avoid paying tax payment notices: 2026 guide
Six lawful ways to cancel, reduce or suspend a tax payment notice (cartella): the five-year limitation period, an appeal to the Tax Court within 60 days, a self-correction request (autotutela), payment by instalments, the 2026 quinquies tax debt settlement scheme and statutory suspension under L. 228/2012. A practical guide with mistakes to avoid and FAQs.

Limitation periods for a tax payment notice (cartella): time limits, calculation and how to invoke them in 2026
A technical guide to limitation periods for a tax payment notice (cartella): 5 or 10 years? Interrupting acts, calculation and how to plead limitation before the tax court.

Trusts and the Italian Supreme Court (Corte di Cassazione): Acts Ineffective Without Express Clauses
In trusts, the Italian Supreme Court (Corte di Cassazione) holds that the settlor's powers are valid only if provided for by express clauses in the trust deed, ensuring the effectiveness of the instrument.

Rottamazione Quinquies 2026: eligibility, savings and deadlines
Rottamazione quinquies 2026: how the new preferential settlement of debts referred to AER works. Eligibility, savings, deadlines, instalments and differences from quater.

Tax Payment Notice Instalment Plans 2026: 120 Instalments, Lapse and New Rules
ADER tax payment notice instalment plans 2026: how to obtain up to 120 instalments, requirements for debts over €120,000, lapse, effects on limitation periods and appeals.

Holding Companies: Contributions and Gifts Do Not Constitute Abuse
The Italian Revenue Agency (Agenzia delle Entrate) clarifies that the combination of a contribution to a holding company and a gift is not abusive if there is economic substance.
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