The new whistleblowing legislation and its impact on the Organizational Model “231”

The Legislative Decree No. 24/2023 introduced important innovations in the field of whistleblowing, by extending also to private companies the obligation to establish internal and external whistleblowing channels. Companies with at least 50 employees, or those in specific regulated sectors, will have to comply by 17th December 2023 The internal channel shall ensure the confidentiality […]

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The Beneficial Owner Register is underway

The Decree of the Ministry of Business and Made in Italy (MIMIT) published on 29 September 2023 has officially established the means of communication for the Register of beneficial Owners. In accordance with the last phrase of art. 3 paragraph 6 of Ministerial Decree 55/2022 (hereinafter also the “Decree”), the communications of data and information […]

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The new ZES tax credit for the investments in southern Italy (“Mezzogiorno”)

With the aim of stimulating the investments in the Italian southern regions (s.c. “Mezzogiorno”), the Italian Government has approved a new law decree, namely the “Southern Decree”, introducing a new benefit called “unified ZES for the Mezzogiorno”. The benefit in question consists of a new tax credit for capital investments applicable from January the 1st […]

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Optional extension of the annual installments for the tax credits for renovation work

Law Decree 176/2022, commonly referred to as the “Decreto Aiuti Quater”, has implemented an additional facilitation pertaining the tax credits deriving from investments in buildings’ renovations. In particular, the new law provides the possibility to benefit from a split allocation over a period of ten years of tax credits recognized for the options such as […]

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Release of carried forward profits in low taxation countries – further provisions

by  Francesco Citerni Paragraphs 87-95 of article 1 of the Law 197/2022 (so-called Budget Law 2023) provided an optional tax incentive to promote the repatriation of carried forward profits by holdings based in low taxation countries. The payment of a reduced substitute tax is required.The incentive consists of a tax relief according by which, at […]

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Surface Right subject to 15% registration tax

By the issuance of the Ruling no. 365/2023, recently published, the Italian Revenue Agency (hereinafter also “the IRA”) released a new relevant opinion on the registration tax rate applicable to the deed of transfer of the surface right on agricultural land. Opposite to the interpretation provided by the Italian Supreme Court in Ruling no. 3461 […]

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Surface Right subject to 15% registration tax

By the issuance of the Ruling no. 365/2023, recently published, the Italian Revenue Agency (hereinafter also “the IRA”) released a new relevant opinion on the registration tax rate applicable to the deed of transfer of the surface right on agricultural land. Opposite to the interpretation provided by the Italian Supreme Court in Ruling no. 3461 […]

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Four ways in which AI can support professionals

Will artificial intelligence really make professionals obsolete? Not only we believe that AI will not replace professionals, yet we are also firmly convinced it could be a great tool to provide a more efficient response to the needs of our clients. Taking advantage of the ongoing discussion on the recent approval of the draft of […]

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Are social networks free?

Anyone who has attempted to subscribe to a social media platform – for cases other than premium subscriptions – would say that such subscription was free: no shopping cart to fill-in, no method of payment, no confirmation upon check-out. Just a bit of box ticking on links to lengthy privacy policies nobody really takes the […]

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The formal breaches’ settlement – clarifications

The Tax Amnesty 2023 Framework, as set forth by Law no. 197/2022 (so called Budget Law 2023) has introduced the opportunity for settling formal tax breaches committed until October 31,2022. The eligible misconducts include irregularities, infractions and noncompliance with legal obligations or binding fulfilments of formal nature. Furthermore, the violations under scope must not have […]

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The regularisation of cryptocurrencies under the Budget Law 2023

Overcoming the previous approach of the Italian Revenue Agency, which wanted to equate them with foreign currencies, the Budget Law 2023 (No. 197/2022) definitively placed crypto-currencies in a new macro-category of instruments called “crypto-assets”, i.e. “a digital representation of value or rights that can be transferred or stored electronically, by using distributed ledger technology or […]

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What legal status for DAOs? Legal and fiscal implications of a regulatory vacuum

The term Decentralised Autonomous Organisations (DAO) identifies the recent phenomenon according to which a group of individuals with a common interest create an organisation coordinated through blockchain technology. In accordance with the definition, such organisation is decentralised – i.e. devoid of central management, whereby decisions are taken by a majority vote of all members of the organisation, […]

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