2018

Prof. Zizzo awarded prize at Top Legal Awards

On 27 November, Prof. Giuseppe Zizzo was awarded the prize for “Supreme Court Litigation Professional of the Year” at the Top Legal Awards 2018, held in Rome.

New tax manual for IAS/IFRS companies by Prof. Zizzo

Prof. Zizzo’s manual entitled, “TAXATION OF IAS/IFRS COMPANIES” will be available from 17 December. The text systematically deals with the rules on the calculation of IRES and IRAP taxable income for companies adopting IAS/IFRS.

Prof. Zizzo finalist at Top Legal Awards

Prof. Giuseppe Zizzo has been selected as a finalist in the Tax Litigation and Supreme Court Litigation Professional of the Year category at the Top Legal Awards 2018. The awards ceremonies will be held in Milan on 19 November 2018 and in Rome in 27 November 2018.

Questions on the “pace fiscale” tax amnesty

Is the “pace fiscale” tax amnesty a measure or merely a half-measure to reduce tax litigation? The settlement of tax disputes, as regulated by art. 6 of Legislative Decree 119/2018, enacts again a measure proposed just over a year ago with art. 11 of Legislative Decree 50/2017.

Registration tax: transfer of a going concern to a company in exchange of its shares followed by the sale of the same shares

The Supreme Court has clearly ruled that, for the purposes of applying registration tax, the transfer of a going concern to a company in exchange of its shares followed by the sale of the same shares should be classified as a direct sale of the going concern. It is therefore crucial to consider very carefully […]

New tax law manual coming soon

Prof. Gaspare Falsitta’s new Tax Law Manual published by Cedam will be published soon. As always, Prof. Giuseppe Zizzo handled the sections regarding business income, corporate income tax and corporate reorganizations.

XXXVI National ANTI (Italian National Association of Tax Lawyers) Conference in Bari

«Tax cooperation measures: implementation status and reform proposals» Prof. Giuseppe Zizzo has been invited to speak at the XXXVI National ANTI Conference (Italian National Association of Tax Lawyers) in Bari on 26 October 2018, with a speech entitled “Advance agreements and exchange of information”. The conference is also sponsored by CFE – Tax Advisers Europe […]

Zizzo e Associati wins in the Supreme Court for Elettrica Trentina Distribuzione Energia Elettrica, an energy supplier

The Supreme Court upheld Prof. Giuseppe Zizzo’s appeal on behalf of the company Elettrica Trentina per la Distribuzione di Energia Elettrica against the Tax Revenue Agency in a case worth more than 6 million Euros. The dispute concerned a payment notice for higher registration tax on a sale of shares which followed the transfer of […]

No short time limit for registration tax

With judgement no. 23670/2018, the Supreme Court recognised that invalidity also applies for registration tax in the event of a failure to communicate the reasons of particular and justified urgency in notices served before the deadline of 60 days from the issue of the tax audit report.

Res iudicata in tax avoidance disputes

With judgement no. 21824/2018, the Supreme Court confirmed that a final judgement delivered with reference to a tax assessment notice for one fiscal year represents res iudicata in disputes relating to tax assessment notices for other years, provided that they are based on the same conditions.

Sustainable taxation for companies

The text of Prof. Giuseppe Zizzo’s speech from 15 September 2017 in Monselice (PD), at the “Sustainable Taxation” conference, organised by the Veneto section of ANTI, has been published in the issue 6/2018 of the Corriere Tributario.

Settlement of tax liabilities and interest due in the case of judicial suspension of the collection proceedings

With judgement no. 3171/2018, filed on 10 July 2018, the Regional Tax Commission of Milan (CTR) ruled that, according to the legislation on the settlement of tax bills, the interest due in the case of judicial suspension of the collection proceedings, must be treated in the same way as interest on late payment and should […]

Dividends paid in cash pooling

With ordinances no. 13933/18 and no. 15477/18, the Supreme Court ruled on two cases of claims for tax refunds by French companies, in accordance with art. 10, par. 4, lett. b) of the Double Taxation Convention (DTC) between Italy and France, with reference to dividends paid by Italian companies via cash pooling.

Are changes to art. 20 of the T.U.R. retroactive?

Prof. Giuseppe Zizzo’s comments on ordinance no. 7637/2018 have been published in issue no. 26/2018 of the Corriere Tributario.

Zizzo e Associati wins Le Fonti prize

Zizzo e Associati has won the Boutique Business of Excellence of the Year – Tax Law Consultancy at the Le Fonti Awards. We are extremely proud of this recognition, which rewards our efforts and dedication.  

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