Chiariti i limiti al riporto delle perdite in caso di fusioni transfrontaliere tra società non residenti

Translated title of the contribution: [Autom. eng. transl.] Limits to carry forward losses in the event of cross-border mergers between non-resident companies clarified

Paolo Arginelli, P. Valacca

Research output: Contribution to journalArticle

Abstract

[Autom. eng. transl.] The article comments on Resolution no. 161 / E of 2017, which addressed the issue of the carry forward of tax losses in the context of a cross-border merger between a French incorporating company and a Luxembourg incorporated company having a permanent establishment in Italy, drawing inspiration from this ruling to practice an organic reconstruction of the positive discipline applicable to the case.
Translated title of the contribution[Autom. eng. transl.] Limits to carry forward losses in the event of cross-border mergers between non-resident companies clarified
Original languageItalian
Pages (from-to)1-4
Number of pages4
JournalRIVISTA DI DIRITTO TRIBUTARIO
Volume2018
Publication statusPublished - 2018

Keywords

  • fusioni transfrontaliere

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